Tradedork Ltd
Customer / User, Website And Platform Privacy Notice
We are committed to respecting your privacy. This notice is to explain how we may use personal information we collect when you:
- subscribe for our services;
- communicate with us about your subscription;
- contact us about our services you are considering subscribing for; or
- browse our website or use our platform.
References to we, our or us in this privacy notice are to Tradedork Ltd. Tradedork Ltd is a limited company incorporated in England and Wales with registered number 14596916 and registered office at Unit 2 Western Avenue Business Park, Mansfield Road, London, United Kingdom, W3 0BZ.
1. Personal information
- When you interact with us, you may provide us with or we may obtain personal information about you, such as information regarding your:
- personal contact details, such as name, telephone number and email address and platform account information, such as your username and password;
- use of our website and platform, such as information about pages that you look at, entry and exit data, content consumed and details of content or services, events and materials that may be of interest to you;
- IP address and other technical information, such as your computer or device’s IP address, and other data collected by the hosting server for statistical purposes, unique device identifiers, network and operating system information, browser type and version, location, time zone settings, browser plug-in types and versions and other cookie related data;
- correspondence with us, such as when you make enquiries, complaints or claims in writing, over the phone or via email, SMS, MMS, or via any other electronic communication system or audio recordings of conversations or voicemails;
- responses to surveys and promotions, attendance at events and marketing preferences;
- financial and payment details, such as bank details, credit card or other payment details; and
- information that you provide to us when interacting with us, to the extent not already covered by the above.
- Depending on the nature of our interactions with you, there may be certain essential personal information that we have to collect from you in relation to your relationship with us. This will vary depending on the relationship we have with you. We may also ask you for additional personal information which it is optional for you to provide but which will allow us to better tailor our relationship with you. For example, you may provide us with additional contact details to make it easier for us to get in touch with you, or with additional information about your preferences to allow us to better tailor your subscription. We will always aim to make it clear which personal information it is necessary for you to provide and which personal information is optional. However, if you are unsure as to whether you are required to provide any particular piece of personal information, please ask.
2. Uses made of the information
- We are committed to protecting your privacy, and will only use your personal information in accordance with applicable data protection legislation, including the UK General Data Protection Regulation and the Data Protection Act 2018.
- The situations in which we will process your personal information are listed below.
To provide products and/or services to our platform users managing subscriptions and administering the contracts we have entered into with platform users
All the personal information we collect
This is necessary to fulfil our contract with you. We have a legitimate interest to properly perform contracts with our users and to manage our relationships with our users.
Validating log-in to our platform and providing access to content
Name, email address, phone number, username and password
This is necessary to fulfil our contract with you. We have a legitimate interest in ensuring that only authorised persons access accounts.
Processing subscription payments or other payments in respect of our services
Name, email address, phone number, payment details
This is necessary to fulfil our contract with you. We have a legitimate interest in ensuring that we are paid for our services.
To build/develop profiles for our platform users or potential platform users
User activity details, usage information, browser and browsing details, preferences, electronic identification information and information collected through cookies
We have a legitimate interest in acquiring information on the content or services our current platform users are using and the content or services our potential platform users customers may want to use.
Publishing content submitted by users to our platform
Username and any personal information contained within the relevant content
We will only publish such content with your consent.
To monitor and maintain our website and platform and other network and communications systems, including conducting data analytics and market research in connection with our website and platform
User activity details, usage information, browser and browsing details, preferences, electronic identification information and information collected through cookies
We have a legitimate interest to monitor and maintain our systems and in obtaining usage feedback to help us to improve our services.
To conduct data analytics studies to review and better understand trends and to improve our business
User activity details, usage information, browser and browsing details, preferences, electronic identification information and information collected through cookies
We have a legitimate interest in understanding our business, the use of our website and platform and social media which relates to us, and those same things in relation to our competitors.
To support network and system security and system auditing
User activity details, usage information, browser and browsing details, electronic identification information and information collected through cookies
We have a legitimate interest in ensuring the security of our IT systems and in auditing our systems.
Carrying out user surveys
Email address and any personal data contained within the responses to the relevant survey
We have a legitimate interest in ensuring that we are providing a positive user experience and understanding content usage patterns.
Carrying out marketing and sending promotional emails
Name, email address, preference data, cookie related data, usage details
We may ask for your consent to process your personal information for this purpose, and you may withdraw or otherwise revoke your consent at any point. If you have purchased services from us previously, we may market similar services as a legitimate interest in developing our business. You have the right to opt out from such marketing at any time.
To hold or conduct events (including promotional events)
Name, email address, telephone number, preference data
We have a legitimate interest in holding events and tracking attendance.
To deal with enquiries or complaints, claims or legal disputes or to raise queries, claims, legal disputes or complaints with you
Name, email address, telephone number and information provided to us in an enquiry, complaint or claim
By submitting information to us in an enquiry, complaint or claim, we will be processing such information with your consent. We have a legitimate interest to respond to enquiries regarding our services, to improve the services and/or products we provide, to ensure that we operate efficiently and to deal with any complaints, claims or other communications received. We also have a legitimate interest in being able to raise queries, claims or complaints of our own and to ensure that all legal claims are managed effectively. To defend, bring or establish legal claims.
To deal with requests from data subjects in relation to exercising their rights
All the personal information we collect
To comply with our legal obligations under data protection laws. We have a legitimate interest in ensuring that requests are dealt with properly and expediently and in constantly improving our data protection procedures and processes in relation to data subject requests.
Storage of records relating to you and also records relating to our business
All the personal information we collect
To comply with our legal obligations in relation to record retention, for example in relation to taxation. We have a legitimate interest in effective record keeping and in keeping proper records in relation to all of our activities.
Business management and planning, including accounting and auditing
All the personal information we collect
We have a legal obligation to have our accounts audited and otherwise have a legitimate interest to effectively plan our business. This is necessary to fulfil our contract with you. We have a legitimate interest to ensure that we operate our business properly and efficiently and to expand our business.
To prevent and detect criminal or improper acts
All the personal information we collect
We have a legitimate interest to ensure that criminal acts are not committed using our systems.
Sale or takeover of our business
All the personal information we collect
We have a legitimate interest in relation to corporate transactions relating to us.
Business continuity
Name, email address, telephone number
We have a legitimate interest in knowing how to contact you and in managing our business upon the occurrence of a business continuity event.
- Some of the above grounds for processing will overlap and there may be several grounds which justify our use of your personal information. We have indicated the main ones above, but these are not exhaustive. We may also use your personal information where we need to protect your vital interests (or someone else’s vital interests) or where it is needed in the public interest, but these instances are likely to be rare. Note that we may also process your personal information without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
- We will only use your personal information for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your personal information for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.
- If you fail to provide certain information when requested or where there is a statutory or contractual requirement, or a requirement necessary to enter into a contract, we may not be able to continue our relationship with you or perform the contract we have entered into with you (such as providing you with our services) or we may be prevented from complying with our legal obligations.
- Where you have given us your consent to use your personal information in a particular manner, you have the right to withdraw this consent at any time, which you may do by contacting us as described in paragraph 10. Please note however that the withdrawal of your consent will not affect any use of your personal information made before you withdrew your consent and we may still be entitled to hold and process the relevant personal information to the extent that we are entitled to do so on bases other than your consent. Withdrawing consent may also have the same effects as not providing the information in the first place, for example we may no longer be able to provide certain services to you.
- You will not be subject to decisions that will have a significant impact on you based solely on automated decision-making, unless we have a lawful basis for doing so and we have notified you.
3. Disclosure of your personal information
- We may share your personal information where it is necessary to administer the relationship that we have with you or where we have a legitimate interest in doing so. We may also disclose your personal information to third parties if we are under a duty to disclose or share your personal information in order to comply with any legal obligation (e.g. to courts or to tax or law enforcement authorities), or in order to enforce or apply such other terms as apply to our relationship, or to protect the rights, property, or safety of our employees, workers and contractors, our users, ourselves or others or where we have a legitimate interest in doing so.
- We may share your personal information with other third parties, for example in the context of the possible sale or restructuring of the business or to our legal or tax advisers. We may also need to share your personal information with a regulator or to otherwise comply with regulatory requirements. We may also share your personal information with our group companies, where this is necessary in relation to our relationship with you.
- ”Third parties” includes third-party service providers (including outsourced service providers such as cloud service, hosting and IT support or maintenance service providers and payment service providers (to the extent necessary for the provider to provide those outsourced services to us or you)). All our third-party service providers are required to take appropriate security measures to protect your personal information.
- We do not allow our third-party service providers who only process data in accordance with our instructions to use your personal data for their own purposes. We only permit them to process your personal data for specified purposes and in accordance with our instructions. Some third parties we share your personal information with process it for their own purposes. This is usually where they are providing you with a product or service directly or fulfilling a regulatory or legal function. This might include for example, tax authorities, regulators, insurance providers or our legal or tax advisers. They should provide you with their own privacy notice which is equivalent to this privacy notice to explain how your personal information will be used.
- We will not share anonymised and aggregated information about our users to third parties, such as advertisers, to allow them to select and send relevant adverts to our users. We may also use such anonymised aggregate information to help advertisers reach the kind of audience they want to target.
- In certain cases the disclosure of your personal information to a third party as described in this paragraph 3 may involve your personal information being transferred outside of the United Kingdom. This may be to:
6.1 a country that is considered to have data protection rules that are equivalent to those in the United Kingdom; or
6.2 a country which is not considered to have the same standards of protection for personal data as those in the United Kingdom, in which case we will take all steps required by law to ensure sufficient protections are in place to safeguard your personal information, including where appropriate putting in place contractual terms approved under the Data Protection Act 2018. - For more information about the circumstances in which your personal information may be transferred outside of the United Kingdom and, to the extent that any such transfers do in fact occur, the safeguards we put in place to protect your personal information, please contact us as described in paragraph 10.
4. Data Security
- We have put in place appropriate security measures to prevent your personal information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who have a business need to know or where there is a legal obligation or permission for them to access your personal information. We have also put in place procedures to deal with any suspected data security breaches or data loss and will notify you and any applicable regulator of a suspected breach where we are legally required to do so.
- However, you should be aware that the method you use to get in contact with us, such as email, may not be entirely secure and your personal information may be susceptible to being intercepted in transit. Equally, your personal information is at risk if a malicious third party gains access to your account on our platform or to any other place where your personal information is stored, such as your email account.
- You should therefore take all reasonable steps to keep your personal information secure, including choosing a secure and unique password for your account on our platform and your email account and not disclosing your passwords to anybody else.
5. Your rights and retention, updating and removal of your personal information
- The duration for which we retain your personal information will differ depending on the type of information and the reason why we collected it from you. However, in some cases personal information may be retained on a long term basis: for example, personal information that we need to retain for legal purposes will normally be retained for at least 7 years in accordance with usual commercial practice and regulatory requirements. Please refer to our Data Retention Schedule for more information.
- It is important to ensure that the personal information we hold about you is accurate and up-to-date, and you should let us know if anything changes, for example if you change your email address. You can update some aspects of your personal information via your platform account or you can contact us using the details in paragraph 10 to update your personal information.
- If you want to stop receiving any information from us, such as news and updates, please let us know by updating your preferences via your platform account, by updating your preferences using the relevant link in any electronic correspondence that you receive from us or by contacting us using the details in paragraph 10. It may take up to one month to unsubscribe you from marketing.
- Your decision to stop receiving information from us may result in the deletion of some of the personal information that we hold about you, but we may still retain personal information we require for other purposes, including where it is required for record keeping purposes.
- Under certain circumstances, by law you have the right to:
5.1 request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
5.2 request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
5.3 request the erasure of your personal information. This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. You also have the right to ask us to stop processing personal information where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground;
5.4 request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
5.5 object to the processing of your personal information based on legitimate interests, but not if we have a compelling reason to process it;
5.6 object to automated decision making (although this does not currently apply as we do not currently carry out automated decision making); and
5.7 request the transfer of your personal information to another party.
- If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, object to automated decision making or request that we transfer a copy of your personal information to another party, please use the contact details in paragraph 10.
- You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive. Alternatively, we may refuse to comply with the request in such circumstances.
- We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to or amended by any person who has no right to receive it or amend it.
6. Direct marketing
- From time to time, we may contact you by email, post, telephone or SMS/MMS or via targeted marketing delivered online through social media and other platforms with information about products or services we believe you may be interested in.
- We will only send marketing information to you in accordance with the marketing preferences set when you initially contact us, when you open your platform account with us, when you refresh your marketing preferences after a request from us to do so, that you otherwise tell us you are happy to receive or where you have purchased similar services or products from us previously.
- From time to time, we may ask you to refresh your marketing preferences by asking you to confirm that you consent to continue to receiving marketing information from us.
- You can let us know at any time that you do not wish to receive marketing information by sending an email to us at info@tradedork.com or by contacting us as described in paragraph 10. You can also unsubscribe from our marketing by clicking on the unsubscribe link in any electronic marketing messages we send to you. This will not stop service messages such as updates regarding the specific services being provided to you and other non-marketing communications from us. It will also not affect marketing or advertising that may appear on our website, platform or other websites.
7. Cookies and log files
When you browse our website or browse or login to our platform, we may use “cookies” to keep track of your visit and give you a better browsing experience. Please refer to our Cookie Policy for further information.
8. Enquiries, issues and complaints
- In the unlikely event that you have any concerns about how we use your personal information, please contact us as described in paragraph 10.
- If we are unable to resolve your complaint, you may make a complaint to the Information Commissioner’s Office. Please see https://ico.org.uk/make-a-complaint/ for more information.
9. Changes to this privacy notice
We reserve the right to alter this privacy notice at any time. Such alterations will be posted on our website. You can also obtain an up-to-date copy of our privacy notice by contacting us as described in paragraph 10. Should you object to any alteration, please contact us.
10. Contacting us
If you need to contact us about this notice or any matters relating to the personal information we hold on you, you can do so via our Data Compliance Manager at info@tradedork.com.
11. Further information
- We hope that the contents of this privacy notice address any queries that you may have about the personal information we may hold about you and what we may do with it. However, if you do have any further queries, comments or requests, please contact us as described in paragraph 10 above.
- Whilst this privacy notice sets out a general summary of your legal rights in respect of personal information, this is a very complex area of law. More information about your legal rights can be found on the Information Commissioner’s website at https://ico.org.uk/for-the-public/.
