Trade Leaf
Privacy Notice

Last Updated:  September 15, 2022

The Trade Leaf website available at https://tradeleaf.io , including any of its subdomains (the “ Website ”) is provided by Trade Leaf Solutions Ltd. ( “ we ”, “ our ”, “ us ” ) . With respect to personal data collected on the Website, we act as a data controller, meaning that we determine the purposes and means of processing your personal data.

In this Privacy Notice we explain how we collect and process your personal data. Personal data or personal information means any information directly or indirectly identifies you as an individual. In this Privacy Notice we use “personal data” and “personal information” as synonyms.

This Privacy Notice also governs the processing of personal data in the official social networks administered by us, which are indicated on the Website  (the “ Communication Networks ”).

We process personal data in accordance with this Privacy Notice and we endeavour to comply with the applicable data protection legislation. If you have any questions regarding processing of your personal data, do not hesitate to contact us via the contact details provided below.

Contact details

Email:          legal@tradeleaf.io

What information we collect

The categories of personal data we collect depend on how you interact with us, the Website, and the requirements of applicable data protection legislation :

1. Contact Data

We may collect certain data if you reach us via (a) the contact form available on the Website or (b) via the contact details indicated in this Privacy Notice or on the Website. In this case, we will collect and process the information related to your request, which includes:

1. email address;
2. name;
3. any other data requested by us or data that you choose to provide us with.

2. Marketing Data

On the Website you may subscribe to receive email newsletters from us regarding the Trade Leaf Project and industry updates. For this purpose you provide us with your email address.

3. Social Media Data

When you access or otherwise participate in the Communication Networks, you may provide certain personal data to us and/or operators of  the Communication Networks. Such personal data may include nicknames, names, photos, messages, comments, communications, and other data that you choose to provide within the Communication Networks.

According to the applicable data protection legislation, we may be considered a data controller or joint controller of such data.

How we use and share the information

1. General

We do not sell or rent out your personal data. However, we may pass your information to our third-party service providers and subcontractors for the purposes of and if it is necessary to provide you with the access to the Website and its functionality. These service providers may include, for instance:

1. our affiliates, meaning any person controlling, controlled by, or under the same control with us;
2. marketing teams;
3. support teams;
4. technical teams;
5. service provider engaged to send email newsletters; and
6. hosting service providers.

We may also disclose your personal data if we are under a duty to disclose or share such data in order to comply with a legal obligation. However, we will endeavour to take reasonable steps to ensure that your rights continue to be protected. In addition, your personal data will be transferred to the government authorities, upon their request or if necessary to comply with a legal obligation, or another entity if we sell or otherwise transfer the Website or its part.

2. Contact Data

The purpose for processing your Contact Data when you contact us is to respond to your inquiry and the legal basis is our legitimate interest to do the same. If and to the extent you wish to enter into a contractual relationship with us, the legal basis for such processing is the necessity to take steps at your request prior to entering into a contractual relationship and further to perform a contractual relationship between you and us.

3. Marketing Data

We process the Marketing Data to send you email newsletters regarding the Trade Leaf Project and industry updates. The legal basis is your consent. Please note that you may unsubscribe from receiving marketing emails at any time by clicking on the unsubscribe button on the bottom of each marketing email or by contacting us with the respective request.

4. Social Media Data

We process the data collected within the Communication Networks for the following purposes:

1. communicate with the visitors, participants, or subscribers;
2. handle requests from visitors via the Communication Networks;
3. obtain statistical information about the reach of the Communication Networks; and
4. conducting customer surveys, marketing campaigns, market analyses, competitions or similar promotions or events.

As a general rule, the legal basis for the processing is our legitimate interest to achieve the above purposes. If and to the extent you wish to enter into a contractual relationship with us, the legal basis for such processing is the necessity to take steps at your request prior to entering into a contractual relationship and further to perform a contractual relationship between you and us.

Please note that the operators of the Communication Networks collect and process personal data to the extent described in their respective privacy policy/notice/statement, which can be found in the respective Communication Network. We may receive certain anonymized statistical information from Communication Networks regarding the use of the accounts operated by us.

With respect to the above processing, we and the operators of the Communication Networks may be regarded as “joint controllers”, meaning that we may jointly determine the purposes and means of processing your personal data. Please note that other than described in this Privacy Notice, we have no influence on the processing of personal data in connection with your use of the Communication Networks. Please contact the operators of the Communication Networks to enforce your rights with respect to the Communication Networks.

How long we process your data

1. General

As a general rule, we keep the data as long as it is necessary for the purposes it was collected. If necessary under the applicable law or to protect our rights and interest or those of third parties, we may process the data longer than outlined below.

2. Contact Data

We store the contact data for one (1) year from the last date when you contacted us regarding the same matter. We set this retention period during the statutes of limitations established in our   Legal Disclaimer . If we enter into a certain engagement or cooperation, or in case of pending legal actions, we process the Contact Data longer.

3. Marketing Data

We process the Marketing Data as long as you remain subscribed to our newsletter.

4. Social Media Data

If not expressly provided otherwise (e.g. in a specific consent form or privacy notice or statement), we will retain your personal data as soon as it is necessary for the purposes mentioned above in the dedicated Social Media Data subsection of this Privacy Notice. We may retain your personal data longer, if it is necessary (1) according to our legal obligations (such as data retention periods provided for by commercial or tax law) or (2) to resolve disputes and lawsuits, exercise or defend legal claims or lawsuits.

Third-party links

The Website may include links and social media plugins to third-party websites and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and applications, and are not responsible for their privacy statements. When you leave the Website, we encourage you to read the privacy policy/notice/statement of every website or application you visit.

Your rights

According to the applicable data protection legislation, you may have the following rights:

• request access  to your personal data (commonly known as a “data subject access request”). This enables you to ask us whether we process your personal data and, if we do process your data, you may request certain information about the processing activity and/or a copy of the personal data we hold about you and to check that we are lawfully processing it;
• request correction  of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us;
• request erasure  of your personal data (commonly known as the “right to be forgotten”) . This enables you to ask us to delete or remove personal data where there is no good reason for us to continue processing it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal or technical reasons which will be notified to you, if applicable, at the time of your request;
• object  to processing of your personal data 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 as you feel it impacts your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms;
• request restriction  of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (1) if you want us to establish the data’s accuracy, (2) where our use of the data is unlawful but you do not want us to erase it, (3) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims, (4) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it;
• request the transfer  of your personal data to you or to a third party (commonly known as the “right to the data portability”) . We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you;
• withdraw consent  at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent;
• not to be subject to a decision based  solely on automated processing of data , including profiling, which produces legal effects concerning you or similarly significantly affecting you; and
• file a complaint  with a relevant supervisory authority in case we violate your rights or obligations imposed on us under the applicable data protection legislation. The relevant supervisory authority may depend on where you are located.

In order to exercise your rights as a data subject, we may request certain information from you to verify your identity and confirm that you have the right to exercise such rights.

Children personal data

The Website is not intended for the use of children (under 18 years old or older, if the country of your residence determines a higher age restriction). We do not knowingly market to, or solicit data from children. We do not knowingly process, collect, or use personal data of children.

If we become aware that a child has provided us with personal information, we will use commercially reasonable efforts to delete such information from our database. If you are the parent or legal guardian of a child and believe that we have collected personal information from your child, please contact us.

Changes to this Privacy Notice

We keep our Privacy Notice under regular review and may update it at any time. If we make any changes to this document, we will change the “Last Updated” date above. Please review this Privacy Notice regularly.