When using our services, we process the personal data of our customers (“you”, “your”, or the “Customer”). This Privacy Policy (the “Policy”) provides information about how your data is processed.

In this Privacy Policy, you will find information regarding the following:

1. Who controls your data, and who should you contact?
2. What information do we collect about you, and how do we obtain it?
3. How do we use your data?
4. How do we store personal data, and how is it secured?
5. To whom do we make your data available?
6. Do we transfer your data to third countries and international organisations?
7. What are your rights, and how can you exercise them?
   

1. WHO IS THE CONTROLLER OF YOUR DATA, AND WHO TO CONTACT?

The controller of personal data is TurboTrade Prop Firm, LLC., Employer Identification Number 36-5088352, with its registered office at 651 N. Broad St, Suite 206, Middletown, Delaware, the United States of America (from now on referred to as TurboTrade.Fund or “we”, “our”, “our Company”, or “Controller”). 

You can contact TurboTrade.Fund at [email protected] with any questions regarding the processing of your data or the exercise of your rights.

2. WHAT INFORMATION DO WE COLLECT ABOUT YOU, AND HOW DO WE OBTAIN IT?

In this section, you can read general information about which of your data we collect and how we collect it. Detailed information on the purposes for which we process personal data is given in Section 3 of this Policy. All information based on which we can directly or indirectly identify you or which is related to you is considered personal data.

We obtain most of the data we collect about you directly from your use of our services. This includes, in particular:

• data that you provide to us yourself, especially when you register on the website, enter information into your user account, order services, participate in our events and projects, or communicate with us through customer support or social networks. This includes identification and contact data, specifically the name, surname, telephone number, e-mail address, postal address, date of birth, user name and password, and business identification number or tax registration number if you are an entrepreneur; payment data, such as bank details; and other data, such as records of communication between you and our company or details of any warranty claims.
• data that we automatically collect when you use our services. This includes data about your device (such as the IP address, device type, operating system, browser used, and connection provider); website usage data (such as the date, time and duration of visit, the country from which you visit the website, website browsing history), and data on the use of services (such as the login and logout information, your account settings, the value of your fictitious capital, your account currency, business strategy).

Some data about you is provided to us by third parties, such as providers of trading platforms that you choose for the use of our services and social network operators if you decide to link your social networking accounts to an account on the website. 

This includes:

data about the simulated transactions you have completed (such as the type of financial instrument, time of opening and closing the position, amount of investment, profit and loss) and data from social networks (user name, profile picture, e-mail address associated with the account on the social network). For information on how your data are processed by trading platform providers and social network operators for their purposes, please refer to the privacy policies of those parties.

3. HOW DO WE USE YOUR DATA?

We use personal data for the following purposes:

• Registration and user account

To use the services, you must register on the website and create an account, and for this purpose, we process your data.

Personal data: identification and contact data; we may also process your data related to the settings of your user account.

Legal grounds for the processing: Processing is necessary for the performance of the contract, and the provision of personal data is required, as we can’t register your user account without them.

• Provision of services and exercise of rights and obligations under the contract between us and the customer

To be able to provide you with our services, i.e. in particular, to provide you with the relevant access, tools and support, and to carry out trades, we need to process your data. For this purpose, the following shall apply:

Personal data: Identification and contact data and, in the case of paid services, also payment data, data on the use of the services, data on the simulated trades and, if you decide to link your social networks accounts with the account on the website, also data from social networks.

Legal grounds for the processing: Processing is necessary for the performance of the contract based on which we provide our services or our legitimate interest. After we stop providing services, we process personal information for a limited period. Such processing is necessary to exercise and protect our rights based on our legitimate interests.

• Marketing communication about our services and products or about events in which we take part

If you are our current or past customer, we may occasionally send you marketing communications related to our services. We may also send you commercial communications to the extent to which you give us your consent. Each e-mail sent will be marked as business communication, and each of the emails will contain a link where you can easily unsubscribe from the business communications. For this purpose, the following shall apply:

Personal data: Identification and contact data.

Legal grounds for the processing: If we have provided you with our services, we may, from time to time, send you marketing communications based on our legitimate interest, namely keeping in touch with our customers. If you give us your consent to process your data for marketing purposes, then we process your data on the basis thereof.

• Customer support and communication

We will process your personal data if you use our customer support services. For this purpose, the following shall apply:

Personal data: Identification data, contact data, and other data from social networks if you contact us through social networks.

Legal grounds for the processing: Processing is based on our legitimate interest, namely in maintaining customer satisfaction and supporting the use of our services.

• Improving services

If you use some of our services, we will process your data to develop, test and enhance the services and improve their security. For this purpose, the following shall apply:

Personal data: Identification and contact data, data about your device, website usage data, data on the use of the services, and data on the simulated trades.

The legal grounds for the processing: Processing is based on our legitimate interest in improving our services.

• Analytics

We analyse customer behaviour to obtain information about how our website and our services are used. For this purpose, the following shall apply:

Personal data: Identification data, contact data, payment data, data about your device, website usage data, data on the use of the services, and data on the simulated trades.

The legal grounds for the processing: Processing is based on our legitimate interest in ascertaining customer behaviour and estimating customer preferences.

4. HOW DO WE STORE YOUR PERSONAL DATA AND HOW IS IT SECURED?

We process your personal data in an encrypted computer and device database. To ensure protection against unauthorised access or unauthorised alteration, disclosure or destruction of the data we collect and process, we have adopted organisational and technical measures to secure them, which we strictly adhere to.

How long do we process your data?

Personal data is processed to the extent necessary to fulfil the purposes described above and for the time needed to achieve those purposes or for a period directly stipulated by law. After that, the personal data is deleted or anonymised. We process personal data for the following periods:

• For the performance of the contract and the exercise of rights and obligations in connection with the contract, including any complaints, settlement of damage claims or related litigation, personal data is processed for the necessary period, but not more than ten years from the termination of the last contract;
• To send business communications without your given consent, personal data is processed for a maximum of 5 years from the expiry of the last contract between us or until you raise an objection or unsubscribe from the business communications;
• To enhance our services, we usually process personal data for a maximum period of 6 months;
• To fulfil our legal obligations, we process personal data for the period set out by the relevant legal regulations (e.g. by tax regulations for ten years from the issuance of the relevant documents for your order);
• If you have given your consent for the period specified in the consent.

5. DATA SHARING and TRANSFERS TO THIRD COUNTRIES

We make your data available or transfer them to persons who help us provide our services, in particular, the following persons:

• The trading platform provider enables you to perform the simulated trades.
• Other third parties that help us run our website and provide our services (such as other companies in our group, hosting and cloud service providers, payment system operators and financial institutions, providers of customer support tools and services, IT companies and system administrators, marketing and communication agencies, consultants and postal service providers).

In addition, we may transfer your data to persons to whom you consent, as well as in cases where it is our obligation under the law or a judicial or any other legally binding decision. Each entity to whom personal data is transferred is contractually obligated to protect your data by legal provisions and to process the data exclusively according to our instructions.

Certain third parties collect personal data for their purposes as controllers. In such a case, their own rules for processing personal data shall apply.

6. YOUR RIGHTS

You can exercise all your rights mentioned below, including the withdrawal of your consent, by sending a request to [email protected]. In connection with the processing of personal data, you have the following rights:

• Right of access to personal data

You can ask us at any time to send you a confirmation as to whether or not your data is being processed. If we process your data, we will provide you with further details on the processing. We will also provide you with a copy of the personal data processed if you request it. Please note that the first copy is free of charge, copies thereafter copies will be provided at a small fee.

• Right to rectification of personal data

If we process your personal data inaccurately, you can notify us of this and we will rectify the inaccurate, personal data without delay. If you register on the Website, you can rectify and amend your personal data by editing your user account.

• Right to erasure of personal data (“right to be forgotten”)

You have the right to obtain from us the erasure of personal data concerning you without undue delay in the following cases:

• if the data is no longer necessary for the purposes for which we have collected or otherwise processed it;
• if you withdraw your consent to the processing and, at the same time, there is no other legal grounds for the processing (this only applies in the cases where we process personal data based on your consent);
• if you object and there is no overriding legitimate grounds for the processing, or if you object to the processing for direct marketing purposes; or
• if your data is processed unlawfully.

We will not be able to act on the request for the erasure of personal data if the processing is necessary for exercising the right of freedom of expression and information, for compliance with any of our legal obligations, for the performance of a task carried out in the public interest, for the establishment, exercise, or defence of our legal claims, or other reasons provided for by law.

• Right to restriction of processing

In cases stated in article 18 of the GDRP, you have the right to obtain restriction of processing of your data from us for a certain period.

• Right to data portability and the provision of data in a machine-readable format

In the case of automated processing based on your consent or performance of the contract, you have the right to receive the data in a structured, commonly used and machine-readable format and to have the date transmitted by us to another personal data controller.

• Right to object

If we process personal data based on our legitimate interest, you have the right to object to such processing. If you file such an objection, we can’t process your data unless we demonstrate compelling, legitimate grounds for the processing which override your interests, rights and freedom or for the establishment, exercise or defence of our legal claims.

If we process your personal data about our products and services for marketing purposes, we will terminate the processing without undue delay upon receipt of the objection. In such a case, we can no longer send you offers of our products and services.

• Right to withdraw consent

If processing is based on your consent, you can withdraw that consent at any time. Withdrawal of consent does not affect the lawfulness of processing based on the consent given before its withdrawal.

• Right not to be the subject of automated decision-making

Except where processing is necessary for entering into, or performance of, a contract, where this is permitted by applicable law or based on your express consent, you have the right not to be the subject of any decision which is based solely on automated processing, including profiling, which produces legal effects concerning you or similarly, affects you to a significant extent.

• Right to complain with the supervisory authority

You can complain to the relevant supervisory authority if you believe we are processing your data and violating legal regulations. 

7. FINAL PROVISIONS

We may change this policy unilaterally, but will do so only when necessary and notify you about such change. You can find the latest version of this policy in your Client Dashboard.