TraderVue Website Privacy Policy

TraderVue Website Privacy Policy

This privacy policy applies between you, the User of this Website and SureSwift Capital Inc., the owner and provider of this Website www.tradervue.com. TraderVue takes the privacy of your information very seriously. This privacy policy applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. Please read this privacy policy carefully.

Definitions and interpretation

  1. In this privacy policy, the following definitions are used:

    1. Data: Collectively all information that you submit to TraderVue via the Website. This definition incorporates, where applicable, the definitions provided in the European Union’s 2018 General Data Protection Regulation (GDPR);

    2. Credit & Debit Card Data: We do not store credit card details on this site nor do we share customer details relating to financial data with any 3rd parties;

    3. Cookies: A small text file may be placed on your computer by this Website when you visit certain parts of the Website and/or when you use certain features of the Website. Details of the cookies used by this Website are set out in the clause below (Cookies);

    4. TraderVue SSC LLC., TraderVue, we or us: TraderVue, owned fully by SureSwift Capital Inc, 113-1834C Oak Bay Avenue, Victoria BC V8R 0A4, Canada;

    5. UK and EU Cookie Law: the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended by the Privacy and Electronic Communications (EC Directive) (Amendment) Regulations 2011 and the European Union’s 2018 General Data Protection Regulation;

    6. User or you: any third party that accesses the Website and is not either (i) employed by SureSwift Capital Inc. and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to SureSwift Capital Inc. and accessing the Website in connection with the provision of such services; and

    7. Website: the website that you are currently using, and any sub-domains of this site unless expressly excluded by their own terms and conditions.  

  2. In this privacy policy, unless the context requires a different interpretation:

    1. the singular includes the plural and vice versa;

    2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;

    3. a reference to a person includes firms, companies, government entities, trusts and partnerships;

    4. “including” is understood to mean “including without limitation”;

    5. reference to any statutory provision includes any modification or amendment of it;

    6. the headings and subheadings do not form part of this privacy policy.

Scope of this privacy policy

This privacy policy applies only to the actions of TraderVue and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites or externally-facing URLs provided throughout the course of using TraderVue.

Data collected

  1. When you initially contact us or use our services, we may collect information that will be relevant to using our services, including :

    1. Your contact information;

    2. Trade information;

    3. Payment information;

    4. Nature of the services or features we can assist you with.  

Our use of Data

  1. For purposes of GDPR, TraderVue acts as a “data controller”.  

  2. We will retain any Data you submit for as long as TraderVue deems it necessary to provide adequate service to the User, unless explicitly asked by a User for their Data to be deleted.  

  3. All personal Data is stored securely in accordance with the principles of the European Union’s General Data Protection Regulation.  

  4. Any or all of the above Data may be required by us from time to time in order to provide you with the best possible service and experience when using our Website. Specifically, Data may be used by us for the following reasons:

    1. internal record keeping;

    2. improvement of our products / services;

    3. Offering and providing services to you;

    4. The ability to make automated decision making, including profiling, only for the purpose of offering a better and more personalized experience for the User or marketing to new users based on information from the users of TraderVue in aggregate; in each case, in accordance with this privacy policy.

Third party websites and services

  1. TraderVue may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services have access to certain personal Data provided by Users of this Website and may be located in various locations throughout the world.  

  2. Any Data used by such parties is used only to the extent required by them to perform the services that we request. Any use for other purposes is strictly prohibited. Furthermore, any Data that is processed by third parties will be processed within the terms of this privacy policy and in accordance with the GDPR.  

  3. Additionally, limited Data can be transmitted to third parties for relevant marketing purposes at the sole discretion of TraderVue. and only in accordance with the GDPR. All opt-outs will be honored.

  4. Tradervue uses the services of the following third parties on this website:

    1. We use Google Analytics to analyze the use of our website. Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/

    2. MixPanel: Tradervue utilizes MixPanel for tracking user-driven events in the web application. MixPanel collects information in accordance with its Privacy Policy.

    3. Hotjar in accordance with its Privacy Policy.

    4. Segment.io in accordance with its Privacy Policy.

    5. Customer.io in accordance with its Privacy Policy.

    6. We use Stripe to process transactions. Their Privacy Policy is available here.

    7. We leverage the services of Trading View. Their Privacy Policy is available here.

    8. This Site is affiliated with CMI Marketing, Inc., d/b/a CafeMedia (“CafeMedia”) for the purposes of placing advertising on the Site, and CafeMedia will collect and use certain data for advertising purposes. To learn more about CafeMedia’s data usage, click here.

Links to other websites

  1. This Website may, from time to time, provide links to other websites. We have no control over such websites and are not responsible for the content of these websites. This privacy policy does not extend to your use of such websites. You are advised to read the privacy policy or statement of other websites prior to using them.

Changes of business ownership and control

  1. SureSwift Capital Inc. may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of TraderVue. Data provided by Users will, where it is relevant and necessary to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this privacy policy, be permitted to use the Data for the purposes for which it was originally supplied to us. All valid opt-outs will be honored.  

  2. We may also disclose Data to a prospective purchaser of our business or any part of it under strict confidentiality and in compliance with the GDPR.  

  3. In the above instances, we will take steps with the aim of ensuring your privacy is protected and that the GDPR is complied with.

Controlling use of your Data

  1. Wherever you are required to submit Data, you will be given options to restrict our use of that Data. This may include the following:

    1. You have the right to ask for a copy of any of your data held by TraderVue.

    2. You have the right to withdraw consent to process your data necessary to use the services provided by TraderVue at any time. This, however, does not apply to instances where TraderVue rely on grounds provided by law, other than consent. Nevertheless, you always have the right to object.

    3. You have the right for your data to be deleted from the servers and databases of TraderVue in accordance with the GDPR.

Please note, however, we may be compelled to terminate your TraderVue product or service where such information is necessary for its delivery. This includes updates on our latest offerings as well as participation in our events, promotions, or other activities.

Functionality of the Website

  1. To use all features and functions available on the Website, you may be required to submit certain Data.  

  2. In order to use the service administered by TraderVue all Users must consent for TraderVue to use your data for purposes TraderVue sees fit as outlined elsewhere in the Privacy Policy. Refusal to offer consent is grounds for TraderVue to block access to services offered by TraderVue.  

  3. A User may revoke consent at any time.  

  4. You may restrict your internet browser’s use of Cookies. For more information see the clause below (Cookies).

Security

  1. Data security is of great importance to TraderVue and to protect your Data we have put in place reasonable physical, electronic and managerial procedures to safeguard and secure Data collected via this Website.  

  2. If password access is required for certain parts of the Website, you are responsible for keeping this password and/or any of your access credentials confidential.  

  3. We endeavor to do our best to protect your personal Data. However, transmission of information over the internet is not always perfectly secure and is done at your own risk. We cannot ensure the security of your Data transmitted to the Website.

Cookies

  1. This Website may place and access certain Cookies on your computer. TraderVue uses Cookies to improve your experience of using the Website and to improve our range of products and services. TraderVue has carefully chosen these Cookies and has taken steps to ensure that your privacy is protected and respected at all times.  

  2. All Cookies used by this Website are used in accordance with current EU Cookie Law.  

  3. When possible, before the Website places Cookies on your computer, you will be presented with a message bar requesting your consent to set those Cookies. By giving your consent to the placing of Cookies, you are enabling TraderVue to provide a better experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of the Website may not function fully or as intended.  

  4. This Website may place the following Cookies:

    • Type of Cookie: Strictly necessary cookies

    • Purpose: These are cookies that are required for the operation of our website. They include, for example, cookies that enable you to log into secure areas of our website, use a shopping cart or make use of e-billing services.

  5. You can choose to enable or disable Cookies in your internet browser. By default, most internet browsers accept Cookies but this can be changed. For further details, please consult the help menu in your internet browser.  

  6. You can choose to delete Cookies at any time; however you may lose any information that enables you to access the Website more quickly and efficiently including, but not limited to, personalisation settings.  

  7. It is recommended that you ensure that your internet browser is up-to-date and that you consult the help and guidance provided by the developer of your internet browser if you are unsure about adjusting your privacy settings.

General

  • You may not transfer any of your rights under this privacy policy to any other person, unless allowed by the applicable Data Privacy Laws. We may transfer our rights under this privacy policy where we reasonably believe your rights will not be affected.  

  • If any court or competent authority finds that any provision of this privacy policy (or part of any provision) is invalid, illegal or unenforceable, that provision or part-provision will, to the extent required, be deemed to be deleted, and the validity and enforceability of the other provisions of this privacy policy will not be affected.  

  • Unless otherwise agreed, no delay, act or omission by a party in exercising any right or remedy will be deemed a waiver of that, or any other, right or remedy.  

  • The Privacy Policy is governed by and interpreted according to the laws of British Columbia. Any dispute, controversy or claim arising under, out of or relating to the validity, interpretation and performance of this Privacy Policy shall be referred to and finally determined by the competent courts of the Province of British Columbia and British Columbia law shall apply.  

  • For any questions or concerns relating to the use of your User Data while using TraderVue, you are welcome to contact the TraderVue’s chosen Data Protection Officer: heyData GmbH, Schützenstraße 5, 10117 Berlin, Germany, www.heydata.eu. Who can be reached by sending an email to datenschutz@heydata.eu and privacy@sureswiftcapital.com.

  • Every user of TraderVue has a variety of rights relating to the use of their data while using TraderVue, including the right to lodge a complaint with a supervisory authority.

ADDITIONAL INFORMATION FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA (EEA) UNDER GDPR

TraderVue would like to make sure you are fully aware of all of your data protection rights. Every user is entitled to the following:

The right to access – You have the right to request TraderVue for copies of your personal data. We may charge you a small fee for this service to cover the costs of retrieval.

The right to rectification – You have the right to request that TraderVue correct any information you believe is inaccurate. You also have the right to request TraderVue to complete the information you believe is incomplete. 

The right to erasure – You have the right to request that TraderVue erase your personal data, under certain conditions.

The right to restrict processing – You have the right to request that TraderVue restrict the processing of your personal data, under certain conditions.

The right to object to processing – You have the right to object to TraderVue’s processing of your personal data, under certain conditions.

The right to data portability – You have the right to request that TraderVue transfer the data that we have collected to another organization, or directly to you, under certain conditions.

If you make a request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us at our email: privacy@sureswiftcapital.com with the subject line of “GDPR Request”. Emails with any other subject line cannot be guaranteed to be responded to within the same timeframe.

EU Representative:

If you are an individual in the EU, you can also contact George Barry, who is based in the Republic of Ireland and has been appointed as TraderVue’s representative in the EU pursuant to Article 27 of the GDPR on matters related to the processing of personal data activities that take place in the EU. To make such an inquiry, please write to George Barry, 4 St. Christopher’s Road, Cork, Ireland.

 

ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA, VIRGINIA, COLORADO, CONNECTICUT, AND UTAH

California law requires us to provide California residents with certain specific information regarding how we collect, use, and share “personal information” as such term is defined in the California Privacy Rights Act and its implementing regulations (“CPRA”, which amended the California Consumer Privacy Act (known as the “CCPA”)).  Following California’s passage of the CCPA, other states have passed similar data privacy laws, including the Virginia Consumer Data Protection Act (“VCDPA”), effective January 1, 2023; the Colorado Privacy Act (“CPA”), effective July 1,2023; the Connecticut Data Privacy Act (“CDPA”), effective July 1, 2023; and the Utah Consumer Privacy Act (“UCPA”), effective December 31, 2023. 

For clarity and ease of reference, we may refer to CPRA, VCDPA, CPA, CDPA, and UCPA collectively as “State Data Privacy Laws”. In the event that one or more State Data Privacy Laws offers more or enhanced rights, privacy, or protections than the State Data Privacy Law applicable to you, we will endeavor to provide you with those additional and/or enhanced rights, privacy, or protection, though we may not be legally obligated to do so.

Sale of Information

CPRA and other State Data Privacy Laws sets forth certain obligations for businesses that “sell” personal information, as “sell” and “sale” are defined in CPRA and the regulations issued thereunder (together with analogous State Data Privacy Laws and their implementing regulations).  While TraderVue does share Personal Information with certain of its service providers and subprocessors to perform the Services and maintain the Platform as described in this Privacy Policy, TraderVue does not “sell” personal information as defined under CPRA and these other State Data Privacy Laws (in other words, we do not accept money or other things of value in exchange for your Personal Information).

California “Shine the Light” Disclosure

The California “Shine the Light” law (Cal. Civ. Code §1798.83) gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the “Shine the Light” law) with third parties for their direct marketing purposes.  TraderVue does not share your personal information (as defined in the “Shine the Light” law) with third parties for their own direct marketing purposes.

“Sensitive” Personal Information

TraderVue may collect, on its own account and/or on behalf of Customers, Personal Information that may be classified as “sensitive” under certain State Data Privacy laws and other privacy laws.   Personal Information that is classified as “sensitive” may be supplied as part of a job application or to facilitate consented to background checks, credential verification and/or other reporting, provided by a third-party to supplement information provided by you, or provided by various service providers, such as benefits providers or insurers and may include one or more of your:

·  social security, driver’s license, state identification card, or passport number.

·  account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account.

·  precise geolocation.

·  racial or ethnic origin, religious or philosophical beliefs, or union membership.

·  contents of mail, email, and text messages (sent through our Platform between you and the business with whom you are applying, for example).

·  Information concerning health, sexual orientation, or sex life (in connection with applying for and receiving health, fertility or other benefits available from an employer, for example).

How We Source, Use, Disclose and Retain Personal Information for Business Purposes

The chart below details the categories of Personal Information we collect from potential customers using the website, the sources of such Personal Information, and how we use, share and retain such information for TraderVue’s business purposes.

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category

Examples

Collected

A. Identifiers.

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers.

YES

B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).

A name, signature, Social Security number, physical characteristics or

 description, address, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

NO

Telephone number,  credit card number, debit card number, or any other financial information

YES

C. Protected classification characteristics under California or federal law.

Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

NO

D. Commercial information.

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

NO

E. Biometric information.

Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

NO

F. Internet or other similar network activity.

Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.

NO

G. Geolocation data.

Physical location or movements.

NO

H. Sensory data.

Audio, electronic, visual, thermal, olfactory, or similar information.

NO

I. Professional or employment-related information.

Current or past job history or performance evaluations.

NO

J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

NO

K. Inferences drawn from other personal information.

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

NO

Personal information does not include:

  • Publicly available information from government records.

  • De-identified or aggregated consumer information.

  • Information excluded from the CCPA’s scope, such as:

    • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data;

    • personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from our clients or their agents. For example, from your signing up on our website or our client’s website

  • Indirectly from our clients or their agents. For example, through information we collect from our clients in the course of providing services to them.

  • Directly and indirectly from activity on our website or those of our clients. For example, from entries through our website portal or website usage details collected automatically.

  • From third-parties that interact with us in connection with the services we perform. 

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason for which the information is provided. 

  • To provide you with information, products or services that you request from us.

  • To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you.

  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.

  • To improve our website and present its contents to you.

  • For testing, research, analysis and product development.

  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.

  • To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

  • As described to you when collecting your personal information or as otherwise set forth in the CPRA.

  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose.  When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose:

Category A:         Identifiers.

We disclose your personal information for a business purpose to the following categories of third parties:

  • Our affiliates.

  • Service providers.

  • Third parties to whom you or your agents authorize us to disclose your personal information in connection with the products or services we provide to you.

In the preceding twelve (12) months, we have not sold any personal information.

Privacy Rights for Residents of California, Virginia, Connecticut, Colorado, Utah, and Residents subject to other State Data Privacy Laws.

If you are a resident of California, Virginia, Connecticut, Colorado, or Utah, applicable State Data Privacy Laws require us to provide you with some additional information about your rights with respect to your “personal information” (as defined in CPRA and similar State Data Privacy Laws). Specifically, CPRA, provides you with the right to:

o   know what personal information we collected about you during certain periods, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we collected about you;

o   delete personal information that we collected from you, subject to certain exceptions;

o   correct inaccurate personal information that we maintain about you;

o   opt-out of the sale or sharing of your personal information, to the extent we sell or share your personal information;

o   limit the use or disclosure of sensitive personal information, to the extent we use such personal information beyond certain express uses, such as in furtherance of providing you our Platform and Services and ensuring their security and integrity;

o   receive non-discriminatory treatment for the exercise of privacy rights conferred by CPRA, including an employee’s, applicant’s, or independent contractor’s right not to be retaliated against for the exercise of their rights described above or otherwise provided in CPRA.

 

One or more of the above rights may be available, in the same or substantially the same form, under one or more of the other State Data Privacy Laws in effect from time to time.  TraderVue respects the privacy of its candidates, its current and former employees, its Customers and their Applicants, and other users of the Platform and Services and will endeavor to honor the above requests regardless of state of residency. 

If you would like further information regarding your legal rights under CPRA or any other State Data Privacy Law or would like to exercise any of the rights available under such laws, please contact us at privacy@sureswiftcapital.com.

We will honor the requests described above and otherwise available to you under applicable Data Privacy Laws, but these rights do not always apply, and exemptions exist that may be relied upon in denying or only partially fulfilling your request. We will usually, in response to a request, ask you to verify your identity and/or provide information that helps us to better understand your request. If we do not comply with your request, we will explain why. With regard to Customer Records, Applicants should direct requests to exercise applicable rights to the Customer on whose behalf we handle the subject Personal Information. If we receive a request from an Applicant directly in relation to Customer Records, we may refer that request to the appropriate Customer(s) and await each such entity’s instructions on how to process the request.

Requests Submitted by Authorized Representatives.

You may submit a request through someone holding a valid Power of Attorney or an authorized agent acting on your behalf.  Authorized agents must have, and provide us with, written permission to make a request on your behalf and must provide necessary information to verify your own identity directly with us.  We will require any purported authorized agent to submit proof of authorization to make requests on your behalf. 

2. ADDITIONAL INFORMATION FOR NEVADA RESIDENTS

Under Nevada law, certain Nevada residents may opt out of the “sale” of “covered information” (as such term is defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons. “Covered information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online. 

We do not engage in such activity; however, if you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of the sale of your covered information under Nevada law by emailing us at privacy@sureswiftcapital.com. Please note we will take reasonable steps to verify your identity and the authenticity of the request.

3. ADDITIONAL INFORMATION FOR NON-U.S. RESIDENTS

TraderVue only collects, processes, stores, and retains as much Personal Information as needed for the specific, identified purposes described in this Policy and/or our respective Customer’s privacy policies that may be applicable to your use of our Services.  TraderVue will not use your Personal Information in any way that is incompatible with the specific, identified purposes described in this Policy.

Personal Data Transfers Outside of the EEA, the UK, Philippines and Singapore

TraderVue operates globally and, to facilitate our global operations, we may transfer your Personal Information to, and store, process, and/or access your personal information in accordance with applicable law from, the various global locations in which TraderVue and/or its personnel operate. This includes the United States. Non-EEA countries may not offer the same level of personal data protection as EEA countries.

If you are located in the EEA, UK, Singapore or other regions with Data Privacy Laws governing data collection and use that may differ from United States Data Privacy Law, please note that we will transfer information, including Personal Information, to a country and jurisdiction that does not have the same Data Privacy Laws and related rights and protections as your jurisdiction, and you consent to the transfer of information to the United States or any other country in which TraderVue, its subprocessors and/or other service providers maintain facilities and the use and disclosure of information about you as described in this Policy.  Please refer to our Subprocessor disclosure for more information.

When your Personal Information is transferred outside the EEA, we will put in place adequate safeguards to ensure that such transfer is carried out in compliance with applicable data protection rules.  An adequate level of protection for your Personal Information and other data may be accomplished using various means, including, where appropriate:

o   notwithstanding the decision of the Court of Justice of the European Union in Case C-311/18, adhering to the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce;

o   relying on a formal decision by the European Commission that a certain country ensures an adequate level of protection for personal data (a full list of such decisions may be accessed online here: 

http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm);

o   entering into appropriate data transfer agreements based on language approved by the European Commission, such as the Standard Contractual Clauses (2021/915/EU, 2010/87/EC and/or 2004/915/EC), or the ICO and UK Parliament, such as the international data transfer agreement (IDTA) and the international data transfer addendum to the European Commission’s standard contractual clauses for international data transfers (Addendum), which are each available upon request at privacy@sureswiftcapital.com;

o   implementing appropriate physical, technical and organizational security measures to protect personal information against accidental or unlawful destruction, accidental loss or alteration, unauthorized disclosure or access, and against all other unlawful forms of processing;

o   taking other measures to provide an adequate level of data protection in accordance with applicable law.

 

BY CHOOSING TO USE THE PLATFORM OR ANY OF OUR SERVICES, YOU EXPRESSLY AGREE THAT ANY DISPUTE OVER PRIVACY OR THE TERMS CONTAINED IN THIS POLICY WILL BE GOVERNED BY THE LAWS OF THE STATE OF CALIFORNIA WITHOUT REGARDS TO ITS CONFLICT OF LAWS PRINCIPLES, AND THE ADJUDICATION OF ANY DISPUTES ARISING IN CONNECTION WITH TRADERVUE OR ITS SERVICES WILL BE IN ACCORDANCE WITH THIS POLICY AND TRADERVUE’S TERMS OF SERVICE .

Rights of Access, Portability, Rectification, Erasure, Withdrawal, and Restriction/Limitation.

You may have the right to inquire as to whether TraderVue is processing Personal Information about you, request access to that Personal Information, request your information in a portable format, restrict or limit certain processing, and ask that we correct, amend, or delete your Personal Information where it is inaccurate.  You may also have the right to withdraw your consent where we previously obtained your consent for certain processing/uses without this withdrawal affecting the lawfulness of any processing that took place prior to the effectiveness of your withdrawal.

You can exercise such rights by accessing, removing, supplementing, and/or correcting the relevant information in your account, submitting a request by emailing privacy@sureswiftcapital.com.  Note that in some cases we may not be able to erase your Personal Information, in which case we will let you know if we are unable to do so and why.

Accessing and Modifying Your Personal Information.

If at any time you believe that an item of Personal Information about you is inaccurate and it cannot be updated through account settings, please contact us as described above as soon as possible with a description of the inaccuracy and the desired correction. We are committed to helping to maintain the accuracy and integrity of Personal Information we hold about you and endeavor to respond to rectification requests in a reasonable timeframe.  Note that we may not be able to modify your information in all circumstances. For example, information we collect in the course of providing the Services is shared with a Customer and we do not control that information once it has been shared with the Customer.

Exercise of Rights Generally.

We will honor the requests described above and otherwise available to you under applicable Data Privacy Laws, but these rights do not always apply, and exemptions exist that may be relied upon in denying or only partially fulfilling your request. We will usually, in response to a request, ask you to verify your identity and/or provide information that helps us to better understand your request. If we do not comply with your request, we will explain why.

If you are not satisfied with our response to any of your requests, you have the right to make a complaint to the data protection authority in the jurisdiction where you live or work, or in the place where you think an issue in relation to your data has arisen. The contact details of each Data Protection Authority can be found at the following website: 

http://ec.europa.eu/justice/data-protection/article-29/structure/data-protection-authorities/index_en.htm.

CHILDREN’S PRIVACY

TraderVue does not knowingly collect, process, maintain or solicit any data, Personal Information, or other information from anyone under the age of 16 or knowingly direct the Services to such persons or otherwise knowingly allow such persons to use the Services. Any individuals under the age of 18 must have consent from their parent or legal guardian to provide Personal Information to TraderVue or otherwise use the Services from their parent or guardian. If we learn that we have collected Personal Information or other data from a child under age 16, we will delete all such information promptly upon becoming aware of the same. If you believe that we might have any information from a child, please contact us as described below .

CHANGES TO THIS POLICY

TraderVue reserves the right to change this privacy policy as we may deem necessary from time to time or as may be required by law. Any changes will be immediately posted on the Website and you are deemed to have accepted the terms of the privacy policy on your first use of the Website following the alterations. 

     

TRADERVUE AFFILIATE PROGRAM – TERMS

  1. If you refer a new customer who signs up for a paid subscription plan, we will pay you 20% of the subscription revenue from that customer for as long as they remain a paid customer. So, for example, if they sign up for the gold plan at $49/mo and remain signed up for 18 months, you’d get a total of $176.40.

  2. If you refer a new customer who signs up for a free plan, but upgrades within 90 days of their initial signup to a paid subscription plan, you will earn commissions on that user as outlined in #1. So, for example, if they signed up for a free account, and 2 months later upgraded to a gold account at $49/mo, and remained signed up for gold for the next two years, you’d get a total of $235.20.

  3. If a paid user cancels their subscription at any time, commissions for that user will cease at that point.

  4. When we record a “click” from your site using your affiliate link, you will get credit for that customer if they sign up within 30 days of that click.

  5. Should we have to refund a customer’s payment for any reason after a commission has already been paid, we will subtract the prorated commission from your ongoing commission balance.

  6. We’ll pay you quarterly via paypal any time your monthly credit balance exceeds $250. If your earnings exceed $500 in a calendar year, we will need your federal tax ID in order to continue payments.

  7. We’ll pay you by the end of a month for the previous month (e.g. May commissions paid by the end of June).

  8. We reserve the right to suspend or terminate your affiliate account at our discretion, for any reason, including but not limited to fraud, excessive chargebacks, misleading statements to us or prospective customers, etc. We will attempt to resolve any such issue with you prior to any suspension or termination.

  9. We reserve the right to change or terminate this program at any time. We will notify you of any such changes.

  10. An affiliate relationship may be terminated at our discretion if no inbound trials and ultimately paid users are recorded in a 6-month period. We want to work only with active affiliates.

  11. If an (affiliate referred) customer becomes eligible for another discount (e.g. yearly subscription, or certain partner discounts), they might no longer be eligible for affiliate commissions at our discretion.

 

CONTACT INFORMATION

If you have any questions or comments about this notice, our Privacy Statement, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: datenschutz@heydata.eu and privacy@sureswiftcapital.com with the subject line of “PRIVACY Request”

Postal Address: 

  • Data Protection Officer,

  • heyData GmbH, Schützenstraße 5, 10117 Berlin,

  • www.heydata.eu, datenschutz@heydata.eu.

     

This Policy was last updated Feb 23th 2024