We, being an entity located in the Denmark, are fully comply with European Union’s (“EU”) General Data Protection Regulation (“GDPR”) which came into effect from 25 May 2018. When this policy mentions “user”, “you, “your” or “Customer”, it refers to data subject in according with the GDPR definitions.
When this policy mentions Tradimo, it refers to the website services, created by the Company.
There are many different ways you can use our services – to search for and share information, to communicate with other people or to create new content. When you share information with us, for example by creating a Tradimo Account, we can make those services even better – to show you more relevant content, to help you connect with people, enjoy Premium services or to make sharing with others quicker and easier. As you use our services, we want you to be clear how we’re using information and the ways in which you can protect your privacy.
As the controller, we have 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, so absolute protection may not be guaranteed. For this reason, every data subject is free to transfer personal data to us via alternative means, e.g. by telephone.
- Personal data
Personal data means any information relating to an identified or identifiable natural person (“data subject”). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.
- Data Subject
Data subject is an identified or identifiable natural person who can be identified, directly or indirectly, based on particular information representing personal data;
Processing is any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction.
- Restriction of processing
Restriction of processing is the marking of stored personal data with the aim of limiting their processing in the future.
Profiling means any form of automated processing of personal data consisting of the use of personal data to evaluate certain personal aspects relating to a natural person, in particular to analyze or predict aspects concerning that natural person’s performance at work, economic situation, health, personal preferences, interests, reliability, behavior, location or movements.
Pseudonymization is the processing of personal data in such a manner that the personal data can no longer be attributed to a specific data subject without the use of additional information, provided that such additional information is kept separately and is subject to technical and organizational measures to ensure that the personal data are not attributed to an identified or identifiable natural person.
- Controller or controller responsible for the processing
Controller or controller responsible for the processing is the natural or legal person, public authority, agency or other body which, alone or jointly with others, determines the purposes and means of the processing of personal data; where the purposes and means of such processing are determined by Union or Member State law, the controller or the specific criteria for its nomination may be provided for by Union or Member State law.
Means any operation or set of operations which is performed on personal data or on sets of personal data, whether or not by automated means, such as collection, recording, organisation, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;
Recipient is a natural or legal person, public authority, agency or another body, to which the personal data are disclosed, whether a third party or not. However, public authorities which may receive personal data in the framework of a particular inquiry in accordance with Union or Member State law shall not be regarded as recipients; the processing of those data by those public authorities shall be in compliance with the applicable data protection rules according to the purposes of the processing.
- Third party
Third party is a natural or legal person, public authority, agency or body other than the data subject, controller, processor and persons who, under the direct authority of the controller or processor, are authorized to process personal data.
Consent of the data subject is any freely given, specific, informed and unambiguous indication of the data subject’s wishes by which he or she, by a statement or by a clear affirmative action, signifies agreement to the processing of personal data relating to him or her.
Processing of personal data
The Company, in its capacity as controller of personal data, processes personal data in a manner that ensures appropriate level of security, including protection against unauthorised or illegal processing and against accidental loss, destruction or damage, while applying suitable technical and / or organisational measures in compliance with the following principles:
- lawfully, fairly and in a transparent manner in relation to the data subject (“lawfulness, fairness and transparency”)
- data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes (“appropriateness in the processing of personal data and purpose limitation”)
- adequate, relevant and limited to what is necessary in relation to the purposes for which they are processed (“data minimisation”)
- accurate and kept up to date
- limitation of the storage for periods not longer than necessary for the purposes for which they are processed (“storage limitation”)
- processed in a manner that ensures appropriate security of the personal data, including protection against unauthorised or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organisational measures (“integrity and confidentiality”).
We process personal data only if and to the extent at least one of the conditions listed below shall apply:
- processing is required for the performance of an agreement with the Company under which the data subject is party or to undertake steps at the request of the data subject prior to the signing of an agreement with us.
- processing is required for compliance with a legal obligation which applies to us in its capacity as controller of personal data.
- the data subject has given consent for the processing of their personal data for one or more specific purposes. In the cases when personal data are processed solely on the grounds of consent, the data subject has the right to withdraw such consent at any time. Withdrawal of the consent of the data subject is not applicable in the cases when the processing of the data is based on the provisions of items “a” and “b” above.
The Company, in its capacity as controller, does not process personal data which reveal racial or ethnic origin, political opinions, religion or philosophical beliefs, trade union membership, and the processing of genetic data, biometric data solely for the purpose of identification of the natural person, data concerning health or data concerning sex life or sex orientation of the natural person unless the data subject have given an explicit consent for the processing of such data for one or more specific purposes.
Name and Address of the controller
Controller for the purposes of the General Data Protection Regulation (GDPR), other data protection laws applicable in Member states of the European Union and other provisions related to data protection is: Tradimo Interactive ApS., located at Lyngbyvej 20, 2100 Copenhagen, Denmark.
Data Protection Officer
Any data subject may, at any time, contact our Data Protection Officer directly with all questions and suggestions concerning data protection via email firstname.lastname@example.org.
We and our partners use various technologies to collect and store information when you visit a Tradimo service, and this may include using cookies or similar technologies to identify your browser or device. We also use these technologies to collect and store information when you interact with services we offer to our partners, such as advertising services.
Cookies are small text files that can be used by websites to make a user's experience more efficient. The new EU law states that we can store cookies on your device if they are strictly necessary for the operation of this site. For all other types of cookies we need your permission.
This site uses different types of cookies. Some cookies are placed by third party services that appear on our pages.
The data subject 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 usable.
Collection of general data and information
We collect information to provide better services to all of our users – from figuring out basic stuff like which language you speak, to more complex things like which course you might like to take next.
We collect information in the following ways:
- Information you give us.
For example, many of our services require you to sign up for a Tradimo Account. When you do, we’ll ask for personal information, like your name or email address to store with your account.
- Information we get from your use of our services.
We collect information about the services that you use and how you use them, like when you watch a video in a course. This information includes:
- Device information
We collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). Tradimo may associate your device identifiers or phone number with your Tradimo Account.
- Log information When you use our services or view content provided by Tradimo, we automatically collect and store certain information in server logs. This includes:
- details of how you used our service, such as the time spent watching a video.
- Internet protocol address.
- device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.
- cookies that may uniquely identify your browser or your Tradimo Account.
- Location information
When you use Tradimo services, we may collect and process information about your actual location to show you the most relevant content in your language or country. We use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide Tradimo with information on nearby devices, Wi-Fi access points and cell towers.
- Unique application numbers
Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to Tradimo when you install or uninstall that service or when that service periodically contacts our servers.
- Local storage
We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.
How we use information we collect
We use the information we collect from all of our services to provide, maintain, protect and improve them, to develop new ones, and to protect Tradimo and our users. We also use this information to offer you tailored content – like giving you more relevant new course suggestions.
We may use the name you provide for your Tradimo Profile across all of the services we offer that require a Tradimo Account.
If you have a Tradimo Account, we may display your Profile name, Profile photo, and actions you take on Tradimo in our services, for example when you make a comment or post. We will respect the choices you make to limit sharing or visibility settings in your Tradimo Account.
When you contact Tradimo, we keep a record of your communication to help solve any issues you might be facing. We may use your email address to inform you about our services, such as letting you know about upcoming changes or improvements.
We use information collected from cookies and other technologies, like pixel tags, to improve your user experience and the overall quality of our services. For example, by saving your language preferences, we’ll be able to have our services appear in the language you prefer.
Tradimo processes personal information on our servers in many countries around the world. We may process your personal information on a server located outside the country where you live (GDPR ‘adequate countries’ only).
Comments function in the blog on the website
We offer users the possibility to leave individual comments on individual blog contributions on a blog, which is on the website of the controller. A blog is a web-based, publicly-accessible portal, through which one or more people called bloggers or web-bloggers may post articles or write down thoughts in so-called blogposts. Blogposts may usually be commented by third parties.
If a data subject leaves a comment on the blog published on this website, the comments made by the data subject are also stored and published, as well as information on the date of the commentary and on the user’s (pseudonym) chosen by the data subject. In addition, the IP address assigned by the Internet service provider (ISP) to the data subject is also logged. This storage of the IP address takes place for security reasons, and in case the data subject violates the rights of third parties, or posts illegal content through a given comment. The storage of these personal data is, therefore, in the own interest of the data controller, so that he can exculpate in the event of an infringement. This collected personal data will not be passed to third parties, unless such a transfer is required by law or serves the aim of the defense of the data controller.
Routine erasure and blocking of personal data
The data controller shall process and store the personal data of the data subject only for the period necessary to achieve the purpose of storage, or as far as this is granted by the European legislator or other legislators in laws or regulations to which the controller is subject to.
If the storage purpose is not applicable, or if a storage period prescribed by the European legislator or another competent legislator expires, the personal data are routinely blocked or erased in accordance with legal requirements.
Rights of the data subject
- Right to information
Each data subject have the right to obtain from the controller the confirmation as to whether or not personal data concerning him or her are being processed. If a data subject wishes to avail himself of this right of confirmation, he or she may, at any time, contact us via email email@example.com.
- Right of access
Each data subject have the right to obtain from the controller free information about his or her personal data stored at any time and a copy of this information. Furthermore, the European directives and regulations grant the data subject access to the following information:
- the purposes of the processing
- the categories of personal data concerned;
- the recipients or categories of recipients to whom the personal data have been or will be disclosed, in particular recipients in third countries or international organizations;
- where possible, the envisaged period for which the personal data will be stored, or, if not possible, the criteria used to determine that period;
- the existence of the right to request from the controller rectification or erasure of personal data, or restriction of processing of personal data concerning the data subject, or to object to such processing;
- the existence of the right to lodge a complaint with a supervisory authority;
- where the personal data are not collected from the data subject, any available information as to their source;
- the existence of automated decision-making, including profiling, referred to in Article 22(1) and (4) of the GDPR and, at least in those cases, meaningful information about the logic involved, as well as the significance and envisaged consequences of such processing for the data subject.
Furthermore, the data subject shall have a right to obtain information as to whether personal data are transferred to a third country or to an international organization. Where this is the case, the data subject shall have the right to be informed of the appropriate safeguards relating to the transfer.
- Right to rectification (if data is not accurate)
Each data subject have the right to obtain from the controller without undue delay the rectification of inaccurate personal data concerning him or her. Taking into account the purposes of the processing, the data subject shall have the right to have incomplete personal data completed, including by means of providing a supplementary statement.
- Right to erasure (Right to be forgotten)
Each data subject have the right to obtain from the controller the erasure of personal data concerning him or her without undue delay, and the controller shall have the obligation to erase personal data without undue delay where one of the following cases applies, as long as the processing is not necessary:
- The personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed.
- The data subject withdraws consent to which the processing is based according to point (a) of Article 6(1) of the GDPR, or point (a) of Article 9(2) of the GDPR, and where there is no other legal ground for the processing.
- The data subject objects to the processing pursuant to Article 21(1) of the GDPR and there are no overriding legitimate grounds for the processing, or the data subject objects to the processing pursuant to Article 21(2) of the GDPR.
- The personal data have been unlawfully processed.
- The personal data must be erased for compliance with a legal obligation in Union or Member State law to which the controller is subject.
- The personal data have been collected in relation to the offer of information society services referred to in Article 8(1) of the GDPR.
If one of the aforementioned reasons applies, and a data subject wishes to request the erasure of personal data stored by us, he or she may contact us via email firstname.lastname@example.org.
Where the controller has made personal data public and is obliged pursuant to Article 17(1) to erase the personal data, the controller, taking account of available technology and the cost of implementation, shall take reasonable steps, including technical measures, to inform other controllers processing the personal data that the data subject has requested erasure by such controllers of any links to, or copy or replication of, those personal data, as far as processing is not required.
- Right of limitation of processing
Each data subject have the right to obtain from the controller restriction of processing where one of the following applies:
- The accuracy of the personal data is contested by the data subject, for a period enabling the controller to verify the accuracy of the personal data.
- The processing is unlawful and the data subject opposes the erasure of the personal data and requests instead the restriction of their use instead.
- The controller no longer needs the personal data for the purposes of the processing, but they are required by the data subject for the establishment, exercise or defense of legal claims.
- The data subject has objected to processing pursuant to Article 21(1) of the GDPR pending the verification whether the legitimate grounds of the controller override those of the data subject.
If one of the aforementioned conditions is met, and a data subject wishes to request the restriction of the processing of personal data stored by the Company, he or she may at any time contact us via email email@example.com.
- Right to transferability (data portability)
Each data subject have the right to receive the personal data concerning him or her, which was provided to a controller, in a structured, commonly used and machine-readable format. He or she shall have the right to transmit those data to another controller without hindrance from the controller to which the personal data have been provided, as long as the processing is based on consent pursuant to point (a) of Article 6(1) of the GDPR or point (a) of Article 9(2) of the GDPR, or on a contract pursuant to point (b) of Article 6(1) of the GDPR, and the processing is carried out by automated means, as long as the processing is not necessary for the performance of a task carried out in the public interest or in the exercise of official authority vested in the controller.
Furthermore, in exercising his or her right to data portability pursuant to Article 20(1) of the GDPR, the data subject shall have the right to have personal data transmitted directly from one controller to another, where technically feasible and when doing so does not adversely affect the rights and freedoms of others.
- Right to object
Each data subject have the right to object, on grounds relating to his or her particular situation, at any time, to processing of personal data concerning him or her, which is based on point (e) or (f) of Article 6(1) of the GDPR. This also applies to profiling based on these provisions.
The Company shall no longer process the personal data in the event of the objection, unless we can demonstrate compelling legitimate grounds for the processing which override the interests, rights and freedoms of the data subject, or for the establishment, exercise or defense of legal claims.
If we processes personal data for direct marketing purposes, the data subject shall have the right to object at any time to processing of personal data concerning him or her for such marketing. This applies to profiling to the extent that it is related to such direct marketing. If the data subject objects to the Company to the processing for direct marketing purposes, we will no longer process the personal data for these purposes.
In addition, the data subject has the right, on grounds relating to his or her particular situation, to object to processing of personal data concerning him or her by the Company for scientific or historical research purposes, or for statistical purposes pursuant to Article 89(1) of the GDPR, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
- Automated individual decision-making, including profiling
Each data subject have the right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning him or her, or similarly significantly affects him or her, as long as the decision (1) is not necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) is not authorized by Union or Member State law to which the controller is subject and which also lays down suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, or (3) is not based on the data subject’s explicit consent.
If the decision (1) is necessary for entering into, or the performance of, a contract between the data subject and a data controller, or (2) it is based on the data subject’s explicit consent, the Company shall implement suitable measures to safeguard the data subject’s rights and freedoms and legitimate interests, at least the right to obtain human intervention on the part of the controller, to express his or her point of view and contest the decision.
- Right to withdraw consent
Each data subject have the right to withdraw his or her consent to processing of his or her personal data at any time.
We shall review and pronounce on the request within 1 month as of its filing.
This period may be extended by further two months, if necessary. The Company informs the data subject as to any such extension within 1 month as of receipt of the request, stating the reasons for the delay. When the data subject files a request by electronic means, the information is provided electronically, if possible, unless the data subject has requested otherwise.
We work with the following service providers who may be processing your data while providing their services to us and save data for the duration that we provide services to you. All of them are world-leading services in their areas and adhere to very strict privacy and data security standards such as “PrivacyShield”, the certification mechanism for US companies. We have concluded strict data processing agreements with these companies that require them to maintain the highest security standards in processing any data:
Google Ireland Limited helps us with our customer service emails if you send an email to firstname.lastname@example.org or email@example.com or any of our team members. They also help us collect insights about our website traffic and usage of our website via Google Analytics and to show advertisement on our website via Google Doubleclick for Publishers. More information about the data processor’s privacy policies here - https://policies.google.com/privacy, https://www.google.com/analytics/terms/us.html.
Adyen BV, Braintree Payments and PayPal Inc. help us process payments. Payment processing and the data collected while doing so is a legal requirement that you cannot opt out of. More information about the data processor’s privacy policies here - https://www.adyen.com/policies-and-disclaimer/privacy-policy, https://www.paypal.com/us/webapps/mpp/ua/privacy-full.
GetResponse Sp. Z o.o. (Polish Limited Liability Company) tracks information such as whether a newsletter was opened and which links were clicked. The purpose of using GetResponse services within our website is to optimize and improve decisions about the future content on our internet page and assessment of the popularity of the content. More information available at https://www.getresponse.com/legal/privacy.html. In case if you wish to cancel newsletters then you can do that easily by clicking on unsubscribe link located of each newsletter email.
Legal basis for the processing
Art. 6(1) lit. a GDPR serves as the legal basis for processing operations for which we obtain consent for a specific processing purpose. If the processing of personal data is necessary for the performance of a contract to which the data subject is party, as is the case, for example, when processing operations are necessary for the supply of goods or to provide any other service, the processing is based on Article 6(1) lit. b GDPR. The same applies to such processing operations which are necessary for carrying out pre-contractual measures, for example in the case of inquiries concerning our products or services. Is our company subject to a legal obligation by which processing of personal data is required, such as for the fulfillment of tax obligations, the processing is based on Art. 6(1) lit. c GDPR. In rare cases, the processing of personal data may be necessary to protect the vital interests of the data subject or of another natural person. This would be the case, for example, if a visitor were injured in our company and his name, age, health insurance data or other vital information would have to be passed on to a doctor, hospital or other third party. Then the processing would be based on Art. 6(1) lit. d GDPR. Finally, processing operations could be based on Article 6(1) lit. f GDPR. This legal basis is used for processing operations which are not covered by any of the abovementioned legal grounds, if processing is necessary for the purposes of the legitimate interests pursued by our company or by a third party, except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject which require protection of personal data. Such processing operations are particularly permissible because they have been specifically mentioned by the European legislator. He considered that a legitimate interest could be assumed if the data subject is a client of the controller (Recital 47 Sentence 2 GDPR).
Processing of your personal data is based on Article 6(1) lit. b GDPR because it’s necessary for the performance of a contract or pre-contractual measures (i.e. Tradimo Account registration) to which the data subject is party in according with Tradimo Terms of Service.
The legitimate interests pursued by the controller or by a third party
Where the processing of personal data is based on Article 6(1) lit. f GDPR our legitimate interest is to carry out our business in favor of the well-being of all our employees and the shareholders.
Period for which the personal data will be stored
The criteria used to determine the period of storage of personal data is the respective statutory retention period. After expiration of that period, the corresponding data is routinely deleted, as long as it is no longer necessary for the fulfillment of the contract or the initiation of a contract.
You may request that we delete your personal Information by contacting us via email firstname.lastname@example.org.
Accessing and updating your personal information
Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.
We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).
Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.
Information we share
We do not share personal information with companies, organizations and individuals outside of Tradimo unless one of the following circumstances applies:
- With your consent
We may share personal information with companies, organizations or individuals outside of Tradimo when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information.
- For external processing
- For legal reasons
We will share personal information with companies, organizations or individuals outside of Tradimo if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary to:
- meet any applicable law, regulation, legal process or enforceable governmental request.
- enforce applicable Terms of Service, including investigation of potential violations.
- detect, prevent, or otherwise address fraud, security or technical issues.
- protect against harm to the rights, property or safety of Tradimo, our users or the public as required or permitted by law.
We may share non-personally identifiable information publicly and with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our services.
We work hard to protect Tradimo and our users from unauthorized access to or unauthorized alteration, disclosure or destruction of information we hold. In particular:
- We encrypt many of our services using SSL.
- We review our information collection, storage and processing practices, including physical security measures, to guard against unauthorized access to systems.
- We restrict access to personal information to Tradimo employees, contractors and agents who need to know that information in order to process it for us, and who are subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.
Children's personal data
If a parent believes that his or her child has submitted personal information to us, he or she shall contact us immediately via email. We will instantly delete that information upon learning that it relates to a child under the age of 16. Please note that it is quite possible that some of this information may continue to be archived in our web logs and some back-up archives, after we delete the information from its active database.
We encourage all parents to supervise their children’s online activities and consider using parental control tools available from different online services.
Existence of automated decision-making
As a responsible company, we do not use automatic decision-making or profiling.