Article 1 — Data controller

TradeTemple, established at Lijsterbeslaan 71, 2181 CL Hillegom, the Netherlands, registered with the Dutch Chamber of Commerce (KvK) under number 98398687, is the data controller for the processing of your personal data as described in this statement.

For privacy-related questions, please contact us via our contact form at https://tradetemplecommunity.nl/contact.

This Privacy Statement has been prepared in accordance with the General Data Protection Regulation (GDPR) and the Dutch GDPR Implementation Act (Uitvoeringswet AVG).

Article 2 — Personal data we process

We may process the following categories of your personal data:

Account and identification data

• Name

• Email address

• Username (Discord, Whop or other platforms)

• Discord ID or comparable platform ID

• Password (stored in encrypted form by our platform providers)

Payment and transaction data

• Payment status and subscription history (via Whop or other payment providers)

• Billing details

• Country of residence (for VAT purposes)

Please note: we do not have access to your full credit card or bank details. These are processed by our payment providers (such as Whop and Stripe).

Communication data

• Messages you send us via the contact form

• Communication via Discord within our community

• Email correspondence

Technical data

• IP address

• Browser type and version

• Operating system

• Pages visited and time of visit

• Referring URL

Usage data

• Interaction with our content and courses

• Progress within educational material

• Participation in community activities

Article 3 — Purposes and legal bases

We process your personal data exclusively for the following purposes, based on the corresponding legal basis under Article 6 GDPR:

Performance of the contract (Art. 6(1)(b) GDPR)

• Providing access to our community, content and courses

• Managing your membership and subscription

• Processing payments

• Communication regarding your account and the services

Legal obligation (Art. 6(1)(c) GDPR)

• Maintaining administration in accordance with tax retention obligations

• Complying with requests from competent authorities

Legitimate interest (Art. 6(1)(f) GDPR)

• Security of our platforms and fraud prevention

• Enforcement of our terms and conditions and community guidelines

Consent (Art. 6(1)(a) GDPR)

• Placement and use of analytical cookies via Google Analytics

• Placement and use of marketing and tracking pixels from Whop and Meta (Facebook/Instagram)

• Measuring conversions and optimising advertising campaigns

• Sending newsletters or marketing communications

You may withdraw your consent for these processing activities at any time via the cookie settings on our website or via our contact form.

Article 4 — Sharing data with third parties

TradeTemple does not sell your personal data to third parties. We share your data only with the following categories of recipients, and only to the extent necessary:

Processors (parties that process data on our behalf):

• Whop (Whop Inc., United States) — platform management, membership management, payment processing and conversion tracking via the Whop Pixel

• Discord (Discord Inc., United States) — community hosting and communication

• Payment providers (such as Stripe) — payment processing

• Hosting provider — hosting of our website and applications

• Email providers — sending transactional emails

Analytics and marketing partners (only on the basis of your consent):

• Google Analytics (Google Ireland Ltd., with transfer to Google LLC in the United States) — analysis of website usage and visitor behaviour. We have configured Google Analytics so that IP addresses are anonymised where possible, and data is not shared with other Google services for Google's own purposes.

• Meta Pixel (Meta Platforms Ireland Ltd., with transfer to Meta Platforms Inc. in the United States) — measuring conversions and optimising advertising campaigns on Facebook and Instagram. The Meta Pixel collects data about your interaction with our website and links it to your Facebook or Instagram account if you are logged in.

• Whop Pixel (Whop Inc., United States) — measuring conversions within the Whop ecosystem for campaign optimisation.

We have concluded data processing agreements with all processors in accordance with Article 28 GDPR. Analytics and marketing partners may act partly as independent data controllers or as joint controllers; please refer to their own privacy statements:

• Google: https://policies.google.com/privacy

• Meta: https://www.facebook.com/privacy/policy

• Whop: https://whop.com/privacy

Third-party recipients:

• Competent authorities, where we are legally required to disclose

• Legal advisers or debt collection partners, where necessary for the protection of our rights

Article 5 — Transfers outside the European Economic Area

Several of our processors and marketing partners — including Discord, Whop, Google (Analytics) and Meta (Pixel) — are established in or transfer data to the United States. Transfers of personal data to countries outside the EEA take place exclusively on the basis of:

• Adequacy decisions of the European Commission, including the EU-US Data Privacy Framework (DPF), insofar as the relevant party is certified under it (both Google and Meta are DPF-certified), or

• Standard Contractual Clauses (SCCs) as approved by the European Commission, or

• Other appropriate safeguards under Chapter V of the GDPR

You should be aware that the United States does not offer an equivalent level of protection to that of the EU, and that US authorities may under certain circumstances gain access to data processed there. By giving your consent for analytical and marketing cookies, you expressly agree to this.

Article 6 — Retention periods

We do not retain your personal data longer than necessary for the purposes for which it was collected:

• Account data: for the duration of your membership and up to 12 months after termination

• Payment and billing data: 7 years, in accordance with the tax retention obligation (Article 52 AWR)

• Communication data: up to 24 months after handling

• Technical and usage data: up to 26 months

• Marketing consent: until you withdraw your consent

After these periods, your data is deleted or anonymised.

Article 7 — Your rights

Under the GDPR, you have the following rights regarding your personal data:

• Right of access — you may request which data we process about you

• Right to rectification — you may have inaccurate or incomplete data corrected

• Right to erasure — you may request that your data be deleted ("right to be forgotten")

• Right to restriction — you may have the processing of your data restricted

• Right to data portability — you may request your data in a structured format

• Right to object — you may object to processing based on legitimate interest

• Right to withdraw consent — where processing is based on consent

You may exercise these rights by contacting us via our contact form at https://tradetemplecommunity.nl/contact. We will respond to your request within 30 days. To verify your identity, we may request additional information.

We are legally required to retain certain data (such as billing records); in such cases, we cannot fully comply with a deletion request.

Article 8 — Cookies and tracking technologies

Our website uses cookies and similar tracking technologies, including pixels. We distinguish four categories:

Necessary cookies — for the functioning of the website and for logging into your account. No consent is required for these.

Functional cookies — for remembering your preferences and settings.

Analytical cookies — placed via Google Analytics for measuring website usage, visitor numbers and visitor behaviour on our site. These cookies are placed only after your consent.

Marketing and tracking cookies — including the Meta Pixel and the Whop Pixel, for measuring conversions, retargeting and optimising advertisements on Facebook, Instagram and within the Whop ecosystem. These technologies are used only with your explicit consent.

On your first visit to our website, we ask for your consent via a cookie banner. You may adjust your preferences at any time via the cookie settings on the website or withdraw your consent via our contact form.

In addition to the cookie settings on our site, you can also limit tracking via:

• Google Analytics opt-out: https://tools.google.com/dlpage/gaoptout

• Meta advertising preferences: via your Facebook or Instagram account settings

• Browser settings: most browsers offer the option to block or delete cookies

Article 9 — Security

We take appropriate technical and organisational measures to protect your personal data against loss, misuse and unauthorised access. These measures include, among others:

• Encryption of data transmission via HTTPS/TLS

• Access restrictions based on role and necessity

• Regular security updates to our systems

• Data processing agreements with all external parties that have access to your data

Despite our careful measures, no system is completely watertight. In the event of a data breach that poses a risk to your rights and freedoms, we will inform you and the Dutch Data Protection Authority in accordance with Articles 33 and 34 GDPR.

Article 10 — Complaints to the supervisory authority

If you disagree with how we handle your personal data, please first contact us via https://tradetemplecommunity.nl/contact, so that we can find a solution.

You also have the right to lodge a complaint with the Dutch supervisory authority:

Autoriteit Persoonsgegevens
Postbus 93374, 2509 AJ Den Haag, the Netherlands
Telephone: +31 88 - 1805 250
Website: https://autoriteitpersoonsgegevens.nl