Privacy Policy

This Privacy Policy describes the ways we collect, store, use and manage the information you provide to us or we collect in connection with our software and websites.

BY CLICKING “I AGREE” BUTTON, USING THE WEBSITE OR DOWNLOADING/INSTALLING THE SOFTWARE YOU AGREE TO THIS PRIVACY POLICY and the processing of your data, including your personal information, in the manner provided in this Policy. If you do not agree to the terms of this document, please do not use the Website or the Software.

1. Definitions

  • “Privacy Policy”, “Policy” means this Privacy Policy.
  • “Terms”, “Terms of Use” means the Website Terms of Use.
  • “We”, “us”, “Website” means the websites accessible at  https://tradeWinger.com, including sub-domains, programming code, related technologies, know-hows, databases and design.
  • “Software” means tradeWinger software
  • “User”, “you” means any person using the Website or the Software.
  • “Personal Data” means information or its combination that can be used to identify you as an individual, such as, for example first and last name.
  • “Anonymous Data” means non-personally identifiable information about an individual that alone or in combination with similar information can not be used to identify you, such as, for example, an IP address or operating system you use.
  • “Information” means collectively any Personal Data, Anonymous Data, information you made publicly available and/or any other protected or publicly available information.

2. Personal Data

To access the Website or the Software and for other purposes that will be mentioned further in this Policy we may process and/or collect the following Personal Data (by the way of example):

  • Your first and last name,
  • Your country and state (if applicable),
  • Your email address.

3. Information We Do Not Collect

We do not process and collect any Personal Data or personally identifiable information, such as (by way of example):

  • Credit card, your e-wallet IDs and similar information,
  • Your address,
  • Any third-party service logins and passwords,
  • Phone numbers.

4. Interactions with Third-Party Log-in Services

If you use your Facebook, Twitter, Google+ or other third-party log-in service (“Third-Party Service”) account information to sign in to the Website or to use the Service, we will collect and store your Third-Party Service user ID. If you connect your account with us with your Third-Party Service account, we ask for your permission to collect certain information from your Third-Party Service account.

We use your Information from such Third-Party Service account only in accordance with your privacy settings you have set up with that Third-Party Service.

5. Anonymous Data Collected Automatically

For you to access and use the Website or the Software we collect Anonymous Data from your computer, mobile device or browser when you use the Website.

The Website automatically collects usage information, such as:

  • Your IP address,
  • The type of device you use,
  • ID or serial numbers of your device or its components,
  • Browser type, version and language,
  • Type and version of your operating system,
  • Your activity on the Website,
  • The number and frequency of visitors to the Website.

We maintain log files of the traffic that visits the Website.

This Anonymous Data is not linked to Personal Data.

6. Cookies. Web Beacons. Third-Parties Links and Ads

We use cookies and other tracking technologies to facilitate access to the Website and to personalize your online experience. Through the use of cookies we may automatically collect Information about your online activity on the Website, such as the web pages you visit and the links you click.

The Website may use cookies to store Information about your preferences or your username and password.

We do not use cookies to store any Personal Data.

We may use web beacons to access cookies and count users who visit the Website or open our emails. Web beacons are single-pixel graphic files with a unique identifier, similar to cookies. Web beacons are embedded invisibly on web pages and are stored on a User’s hard drive. You can modify your browser settings to control web beacons.

The Website may contain links and advertisements leading to other sites. This Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer. For example, third party websites to which a link points may set cookies on your computer. Some of these services may be used to track your behavior on other websites and we have no control over this.

We are not responsible for the privacy practices of linked or advertised sites. We strongly recommend that you read the privacy policies of the linked or advertised websites as they may contain further terms and conditions which apply to you.

7. Why We Collect Information

The Information is used for:

  • Delivering you the Software and its functionality,
  • Provision of updates and support for the Software,
  • Billing and accounting purposes,
  • Your seamless interaction with the Website or the Software,
  • Analytical and statistical purposes,
  • Understanding of our User’s interaction with the Website or the Software,
  • Improvement and development of the Website, the Software or our other services and products,
  • Enforcement of this Policy and the Terms of Use.
  • Sending you related information, including promotions, special offers, confirmations, newsletters, updates, and security alerts.

When possible, we always use the Information anonymously in aggregation with similar information from other Users of the Website.

8. How Long We Retain Information

The time periods for which we retain your Information depend on the purposes for which we use it. We will keep your Information for as long as you are a User and, thereafter, for no longer than is reasonably necessary for reporting and reconciliation purposes pursuant to legal requirements and to provide you with any feedback or information you might request or require.

9. Your Consent

YOU EXPRESSLY CONSENT TO OUR PROCESSING, COLLECTION, TRANSFER, STORAGE, DISCLOSURE AND OTHER USES OF YOUR INFORMATION AS DESCRIBED IN THIS POLICY, LICENSE AGREEMENT AND THE TERMS OF USE AT INSTANCE WHEN YOU:

  • PROVIDE INFORMATION TO US THROUGH THE WEBSITE OR THE SOFTWARE; AND/OR
  • ACCEPT THIS POLICY.

IN ADDITION, THROUGH THIS USE AND INTERACTIONS WITH THE WEBSITE AND THE SOFTWARE YOU SPECIFICALLY CONSENT TO:

  • OUR COLLECTION OF INFORMATION BY AUTOMATED MEANS, SUCH AS COOKIES, WEB BEACONS OR THE INTENDED FUNCTIONALITY OF THE WEBSITE, AND TO OUR SUBSEQUENT PROCESSING AND USING OF INFORMATION IN ACCORDANCE WITH THIS POLICY, AND
  • THE STORAGE AND TRANSFER OF INFORMATION TO LOCATIONS WHEREVER WE AND OUR SERVICE PROVIDERS HAVE FACILITIES.

10. With Whom We Share the Information

We may share Information we collect under any of the circumstances mentioned in this Policy and/or the Terms of Use.

We may share Information with selected third parties, including payment service providers, our advisors, advertisers and contractors.

11. Disclosure of Information

We may release the Information concerning your use of the Website or the Software:

  • To provide you with the services according to the the Terms of Use.
  • When we believe in good faith that such release is appropriate to comply with the applicable law, regulation, legal process or governmental request (for example, pursuant to a statutory demand, subpoena, warrant or court order);
  • To enforce this Policy and/or the Terms of Use, or any agreement between you and us;
  • To detect, prevent, or otherwise address fraud, security or technical issues;
  • To protect against abusive or unlawful use of the Website or the Software;
  • To protect the rights, safety, or property of Users, or any other third parties;
  • If we reasonably believe that a situation involving danger of death or injury to any person requires disclosure;
  • In other ways described in this Policy and the Terms of Use.

12. Information Concerning Children

We do not knowingly collect or solicit Information from anyone under the age of 13 or knowingly allow such persons to use the Website or the Software. If we become aware that we have collected Personal Data from a child under age 13 without verification of parental consent, we take immediate steps to remove that Personal Data.

13. Sensitive Personal Data

We do not deal with any sensitive information, such as related to the racial or ethnic origin, political opinions, religious beliefs, physical or mental health or condition, crime or court records, etc.

14. Information Security

We will take commercially reasonable precautions to protect Personal Data from loss, misuse and unauthorized access, disclosure, alteration and destruction. We process all Information using industry-standard techniques.

We implement the following administrative, technical, and physical measures for the protection of Personal Data:

  • Administrative measures. Access to your Personal Data is limited to authorized personnel who have a legitimate need to access it based on their job descriptions. In case third-party contractors process Personal Data on our behalf, similar requirements are imposed.
  • Technical measures. We use up-to-date firewall protection and high-quality antivirus and anti-malware software.
  • Physical measures. Access to Personal Data is not permitted via the Internet except using an encrypted virtual private network. Otherwise access is limited to our physical premises. We store Personal Data on servers provided by third party hosting vendors with whom we have contracted.

However, we do not guarantee or warrant that such techniques will prevent unauthorized access to Information, including Personal Data that we store.

15. Business or Asset Transfer

In the event that we, a line of our business, or substantially all our assets are transferred, sold or merged with another business, Information may be one of the transferred assets.

16. Modifications

We reserve the right, at our sole discretion to modify or revise this Policy at any time by posting the amended Policy on the Website. Please check the most current Policy.

Your continued use of the Website or the Software after a change or update has been made will constitute your acceptance to the revised Privacy Policy. If you do not agree with the modifications, please discontinue use of the Website and the Software.

17. Changing or Updating Your Personal Data

We take reasonable steps to ensure that the Personal Data we hold about you is accurate, complete and up-to-date. However, we rely on you to advise us of any changes to your Personal Data.

Please contact us as soon as possible if there are any changes to your Personal Data or if you believe the Personal Data we hold about you is not accurate, complete or up-to-date so that we can update our records accordingly.

18. Privacy Related Inquiries

If, for any reason, you are concerned with the way that we may be using your Personal Data, you have questions about the privacy aspects of the Website or the Software, please, contact us at info@tradewinger.com

Last updated: July 29, 2017