- About this Policy
- Your Rights
- How do we collect your personal data?
- What personal data do we collect from you?
- What do we use your personal data for?
- Sharing your personal data
- Data retention and deletion
- Keeping your personal data safe
- California Online Privacy Protection Act
- CAN-SPAM Compliant
- How to contact us
Last updated on June 15, 2018
- About this Policy
- Ensure that you understand the personal data we collect about you, the reasons why we collect and use it, and who we share it with;
- Explain the way we use the personal data that you share with us in order to give you a great experience when you are using the Simpler Services; and
- Explain your rights and choices in relation to the personal data we collect and process about you and how we will protect your privacy.
- Your Rights
Thank you for choosing Simpler Trading!
At Simpler Trading, we want to give you the best possible experience and most useful educational resources and training. To do this, we need to understand your needs and wants so we can deliver exceptional service specifically for you. That said, your privacy and the security of your personal data is, and will always be, enormously important to us. While the use of Simplertrading.com (“Site”) is possible without any indication of Personal Data, if a data subject wants to use special enterprise services via our website, processing of personal data could become necessary. In processing this data, we want to transparently explain to you how and why we gather, store, share and use the personal data, as well as outline the controls and choices you have around when and how you choose to share your personal data.
As the controller, Simpler Trading has implemented numerous technical and organizational measures to ensure the most complete protection of personal data processed through this website. However, Internet-based data transmissions may, in principle, have security gaps. Absolute protection is not guaranteed. For this reason, every data subject is free to transfer personal data to Simpler Trading via alternate means, e.g. by telephone.
This Policy sets out the essential details relating to your personal relationship with Simpler Trading. The Policy applies to all Simpler Trading services and any associated services (referred to as the “Simpler Services”). The terms governing your use of the Simpler Services are defined in our Terms and Conditions (“Terms and Conditions”).
From time to time, we may develop new or offer additional services. If the introduction of these new or additional services results in any change to the way we collect or process your personal data, we will provide you with more information and additional terms or policies. Unless stated otherwise when we introduce these new or additional services; they will be subject to this Policy.
The aim of this Policy is to:
We hope this helps you to understand our privacy commitments to you. For information on how to contact us if you ever have any questions or concerns, please see Section 16 below. Alternatively, if you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the Simpler Services.
Under the new European Union law, General Data Protection Regulation (“GDPR”), certain individuals are granted certain rights in relation to their personal data. You have the following rights when submitting your personal data to us:
- Right of Access – the right to be informed of and request access to the personal data we process about you;
- Right to Rectification – the right to request that we amend or update your personal data where it is inaccurate or incomplete;
- Right to Erasure – the right to request the deletion of your personal data;
- Right to Restrict Processing – the right to request that we temporarily or permanently stop processing some or all of your personal data;
- Right to Data Portability – the right to request your data in a structured, commonly used and machine-readable format and the right to transmit that personal data for use in another party’s service; and
- Right not to be subject to Automated Decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.
We collect your personal data in the following ways:
- When you visit our Site – when you visit our Site, we collect certain personal data to help increase data protection, data security and ensure an optimal level of protection for the data that we process.
- When you sign up for Simpler Services – when you sign up for a Simpler Service, we collect certain personal data so you can use the Simpler Service, such as your email address, birth date, name, and payment information.
- Personal data collected that enables us to provide you with additional features/functionality – when you sign up for additional materials from Simpler Trading, such as our nightly newsletter or other marketing materials, or contact Simpler Trading’s customer service through the Site, or participate in our blog comments, we collect certain personal information about you. You will always have the option to change your mind and withdraw your consent at any time.
- From third parties – we will receive personal data about you and your activity from third parties, including advertisers and partners we work with in order to provide you with the Simpler Service. We will use this personal data either where you have provided your consent to the third party or to Simpler to that data sharing taking place, or where Simpler has a legitimate interest to use the personal data to provide you with the Simpler Service.
We have set out in the tables below the categories of personal data we collect and use about you:
Personal data collected when you visit our Site
This is the personal data that is collected by us to help optimize your experience when visiting our Site, as well as increase data protection, data security and ensure an optimal level of protection for the data we process.
We collect the following general data when you visit our site: (1) the browser types and versions used; (2) the operating system used by the accessing system; (3) the website from which an accessing system reaches our Site (so-called referrers); (4) the sub-websites; (5) the date and time of access to the Internet site; (6) an Internet protocol address (IP address); (7) the Internet service provider of the accessing system; and (8) any other similar data and information that may be used in the event of attacks on our information technology systems.
When analyzing this general data, Simpler Trading does not draw any conclusions about the data subject. Rather, we analyze the anonymously collected data and information statistically and anonymous data of the server log files are stored separately from all personal data provided by a data subject.
Personal data collected when you sign up for the Simpler Service
Account Registration Data
This is the personal data that is provided by you or collected by us to enable you to sign up for and use the Simpler Service. This includes your first and last name, email address, credit card number, billing address, and other information required to process your payment.
By registering on our Site, the IP address (assigned by the Internet service provider (ISP) and used by the data subject), date and time of registration are also stored. The storage of this data takes place against the background that this is the only way to prevent the misuse of our services, and if necessary, to make it possible to investigate committed offenses.
We may collect such personal data if you sign up for a Trial, Membership, Seminar or Software (as defined in our Terms and Conditions). The following personal data collected will vary, but will include information such as:
- Credit or debit card type, expiration date, and certain digits of your card number;
- Postal code;
- Mobile phone number; and
- Details of your transaction history.
Personal data collected that enables us to provide you with additional features and functionality
Subscription to our Nightly Newsletter and Daily Video
This is the personal data that is provided by you to subscribe to our Nightly Newsletter and Daily Video. This includes your name and a valid email address. A confirmation email will be sent to the e-mail address registered by data subject for double opt-in purposes. This confirmation e-mail is used to prove whether the owner of the e-mail address as the data subject is authorized to receive the newsletter.
During the registration for the newsletter, we also store the IP address of the computer system assigned by the Internet service provider (ISP) and used by the data subject at the time of registration, as well as the date and time of the registration. The collection of this data is necessary to understand the (possible) misuse of the e-mail address of a data subject.
You can unsubscribe from the email at any point in time. You may be contacted via email in the case that the newsletter offer is modified, canceled or materially changed, or in the event of a change in technical circumstances.
This personal data is used to enable Simpler and our partners/service providers to send you marketing communications either:
- Via email;
- Whilst using Simpler Service; and/or
- Direct from the third party
You can unsubscribe from the email at any point in time.
Contact via Website
The Site contains information that enables a customer to quickly engage our customer service team via email or a contact form. If a data subject contacts via email or a contact form, we may collect the following information: name, email address and phone number.
Blog Comments Data
The Site allows for data subjects to leave comments on a blog published on the Site. If a data subject willingly leaves a comment on a blog, the comment made by the data subject, as well as the date and time of the comment and the data subject’s username are published on the site.
In addition, the IP address assigned by the Internet Service Provider (ISP) to the data subject is also logged.
Finally, if a data subject subscribes to follow comments on a blog post, we will collect their email address. An automatic confirmation email to check the double opt-in will be sent to the email. The option to subscribe to comments may be terminated at any time.
When you use or interact with the Site, we use a variety of technologies to process the personal data we collect about you for various reasons. We have set out in the table below the reasons why we process your personal data, the associated legal basis we rely upon to legally permit us to process your personal data, and the categories of personal data (identified in Section 5) used for these purposes:
To increase data protection and data security of our enterprise, to ensure an optimal level of protection for the personal data we process, and to optimize your use of SimplerTrading.com
- Legitimate Interest
- General Data
- Blog Comments Data
To provide, personalize and improve your experience with the Simpler Service(s) and other services and products provided by Simpler, for example by providing customized or personalized content, recommendations, features and advertising on or outside of the Simpler Service (including for third party products or services)
- Performance of a Contract
- Legitimate Interest
- Account Registration Data
- Payment Data
To send out our Nightly Newsletter and Daily Video to subscribers
- Legitimate Interest
- Subscription to our Nightly Newsletter and Daily Video
To process your payment to prevent or detect fraud including fraudulent payments and fraudulent use of Simpler Services
- Performance of a Contract
- Compliance with legal obligations
- Legitimate Interest
- Payment Data
To communicate with you, either directly or through one of our partners, for:
- Participation in contests, surveys and sweepstakes
- Promotional purposes
Via emails, notifications, or other messages, consistent with any consent you may have communicated to us or if there is a legitimate interest based on the Services you have purchased from us
- Legitimate Interest
- Marketing Data
To respond to customer inquiries
- Contact via Website
We have set out the categories of recipients of the personal data collected or generated through your use of the Simpler Service.
Publicly available information
The following personal data will always be publicly available on the Simpler Service: your username and the date and time if you leave a comment on a blog post on the Site.
Personal data we may share
Service Providers and Others
We use technical service providers which may operate the technical infrastructure that we need to provide the Simpler Service, in particular providers which host, store, manage and maintain the Simpler site and application, its content and the data we process.
We use technical service providers to help us communicate with you, as described in Section 6 of this Policy.
We use marketing and advertising partners to show you more tailored content, or to help us better understand your use of the Simpler Service, to provide you with a better experience. We also may share personal data with certain marketing and advertising partners to send you promotional communications about Simpler.
If you access the Simpler Service through an offer that you received or purchased from a third party, we share personal data with that third party about your use of the Simpler Service, such as whether and to what extent you have used the offer, activated a Simpler account, or actively used the Simpler Service.
Law Enforcement and Data Protection Authorities
We will share your personal data when we in good faith believe it is necessary for us to do so to comply with a legal obligation under applicable law, or respond to valid legal process, such as a search warrant, a court order, or a subpoena.
We also will share your personal data where we in good faith believe that it is necessary for our own, or a third party’s legitimate interest relating to national security, law enforcement, litigation, criminal investigation, protecting the safety of any person, or to prevent death or imminent bodily harm, if we deem that such interest is not overridden by your interests or fundamental rights and freedoms requiring the protection of your personal data.
Purchasers of our business
We keep your personal data only as long as necessary to provide you with Simpler Service and for legitimate and essential business purposes, such as maintaining the performance of the Simpler Service, making data-driven business decisions about new features and offerings, complying with our legal obligations, and resolving disputes. We keep some of your personal data for as long as you are a user of the Simpler Service.
If you request, we will delete or anonymize your personal data so that it no longer identifies you, unless, we are legally allowed or required to maintain certain personal data, including situations such as the following:
- If there is an unresolved issue relating to your account, such as an outstanding credit on your account or an unresolved claim or dispute we will retain the necessary personal data until the issue is resolved;
- Where we are required to retain the personal data for our legal, tax, audit, and accounting obligations, we will retain the necessary personal data for the period required by applicable law; and/or,
- Where necessary for our legitimate business interests such as fraud prevention or to maintain the security of our users.
We may display advertisements and offers from third parties and other content that links to third-party websites. We cannot control or be held responsible for third parties’ privacy practices and content. If you click on a third-party advertisement or link, please understand that you are leaving the Simpler Service and any personal data you provide will not be covered by this Policy. Please read their privacy policies to find out how they collect and process your personal data.
We are committed to protecting our users’ personal data. We implement appropriate technical and organizational measures to help protect the security of your personal data; however, please note that no system is ever completely secure. We have implemented various policies including pseudonymization, encryption, access and retention policies to guard against unauthorized access and unnecessary retention of personal data in our systems.
Your password protects your user account, so we encourage you to use a unique and strong password, limit access to your computer and browser and log out after having used the Simpler Service.
You may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely used.
The Simpler Service is not directed to children under the age of 18 years. However, in some countries, stricter age limits may apply under local law. Please see our Terms and Conditions for further details.
We do not knowingly collect personal data from children under 13 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use the Simpler Service, and do not provide any personal data to us.
If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to Simpler, please contact us at email@example.com, and you may request exercise of your applicable rights detailed in Section 3 of this Policy.
If we learn that we have collected the personal data of a child under the age of 13 years, we will take reasonable steps to delete the personal data. This may require us to delete the Simpler account for that child.
- You may visit our site anonymously
- You can change your personal information by emailing us at firstname.lastname@example.org
We may occasionally make changes to this Policy.
When we make material changes to this Policy, we’ll provide you with prominent notice as appropriate under the circumstances, e.g., by displaying a prominent notice within the Simpler Service or by sending you an email. We may notify you in advance.
Please, therefore, make sure you read any such notice carefully.
If you want to find out more about this Policy and how Simpler uses your personal data, please contact us at email@example.com.
Simpler Trading is CAN-SPAM compliant, which allows for you to request we stop sending you emails. Our emails contain “unsubscribe” options, which you may use to stop receiving emails from Simpler Trading. If you have any issues unsubscribing from our emails, please contact firstname.lastname@example.org.
Simpler Trading, LLC
4300 N Quinlan Park Rd. #120
Austin, TX 78732