Privacy Policy
TradeWing, Inc. (“TradeWing”, “we”, “our” or “us”) is committed to protecting the privacy of those who entrust us with their personal information. Our users trust and expect that we will protect their personal information in accordance with the promises we make. “Personal information” means any information pertaining to an identified or identifiable individual and may include, for example, email addresses and contact details and any similar information provided to us in the course of our business operations. Information that is de-identified or anonymized is not considered personal information. This Privacy Policy details our commitment to your privacy.
1. What does this Privacy Policy cover?
TradeWing is a cloud-based platform for driving member engagement through the use of online communities. This Privacy Policy describes our privacy practices regarding personal information we receive in connection with the products and services we provide to our clients (the “Client Services”), as well as through our website (the “Site”).
By using the Client Services, visiting the Site or otherwise interacting with us, you are accepting the practices described in this Privacy Policy. We recommend that you review this Privacy Policy periodically, as it may be updated from time-to-time.
2. What information does TradeWing collect, and how is it used and shared?
For the 12-month period prior to the date of this Privacy Policy, we explain here what categories of personal information we have collected, the purpose of collection, and how we share it:
| Category of Personal Information Collected | Source | Purpose for Collection | Categories of Recipients |
|---|---|---|---|
| Contact information: such as name and email address | From you when you register for or enroll in the Site or any Client Services (or on your behalf when you are registered or enrolled in connection with an entity or group) | To provide, manage, support, improve and personalize the Site and Client Services and any related transactions, and to communicate with and respond to you about the Site or Client Services, including to validate your identity or to meet legal obligations | Our affiliates, agents and successors; to the extent relevant, select marketing, technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable, an entity or group under which you are registered or enrolled |
| Forum information: such as information you enter into any forum or other collaborative environment or communication tool available on or through the Site or Client Services | From you when you input information into any such environment or tool | To collaborate and communicate, as contemplated by such environment or tool | Users who are authorized to view or use such environment or tool (or the applicable portion thereof) or to whom such information is communicated or designated; our affiliates, agents and successors; and, to the extent relevant, select technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations) |
| Browsing information: such as your IP address or other device identifier, the kind of browser or device you use, pages and content that you visit on the Site, what you click on, the state and country from which you access the Site or Client Services, date and time of your visit, and web pages you linked to the Site from | The Site or Client Services or your interactions with the Site or Client Services, including through the use of cookies or other tracking technologies explained further below | To evaluate usage of the Site and Client Services and improve functionality and performance; to protect the security and integrity of the Site and Client Services and our business, such as preventing fraud, hacking, and other criminal activity or to meet legal obligations | Our service providers who help us with fraud protection and website analytics |
| Payment information: such as name, card issuer and card type, credit or debit card number, expiration date, CVV code, and billing address | From you or your payment card issuers | Authorizing of credit card and other financial transactions with respect to your subscription or other payment obligations, as applicable, related to the Site or Client Services | Our service providers who process payments for us—they are prohibited from using personal information for any other purposes and are contractually required to comply with all applicable laws and requirements, which includes the Payment Card Industry Data Security standards |
| Legal process-related information: such as details of your identity, or suspected or alleged criminal, dangerous, impermissible, unlawful or other relevant behavior | From crime and fraud prevention agencies, you, witnesses or law enforcement agencies | To protect users, the public and our business against risks and crime | Law enforcement and other governmental authorities in accordance with applicable law, our technical and other service providers, and our professional advisors |
TradeWing will only use personal information to the extent it is reasonably necessary to deliver, manage, support, improve or personalize the Client Services or the Site. In some jurisdictions, individuals may have the right to withdraw consent from certain uses. If you reside in such jurisdictions, you may have additional rights which are detailed in sections 8 through 10. In all cases, any service providers will be contractually limited in the way they may use personal information maintained by TradeWing, including requirements that such information be maintained in a confidential and secure manner.
In Connection with Business Transfers: In the event that a division, a product or all of TradeWing is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law.
To Comply with Laws: TradeWing may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our users or others, in accordance with or as authorized by law.
3. What are cookies and how do we use them and other technologies?
A cookie is a small piece of information that a website, online application, or email may save to your browser or your computer’s hard drive for use in subsequent visits to the website or online application. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies or how to disable cookies altogether. If you reject cookies, you may not be able to participate in certain activities or receive a promotion tailored to you. TradeWing does not control and does not guarantee the effectiveness of browser-based tools for managing cookies.
TradeWing does not currently participate in interest-based or behavioral online advertising, and information automatically collected from the Site is not used by TradeWing for that purpose.
TradeWing may use Google Analytics to evaluate use of the Site for our internal purposes such as evaluating usages of the Site. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.
Any and all personal information collected on the Site will be kept strictly confidential and will not be sold, reused, rented, disclosed, or loaned to third parties, except as otherwise described in this Privacy Policy.
Do Not Track (DNT): This is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium, or W3C, has not yet established universal standards for recognizable DNT signals, and therefore TradeWing and the Site do not recognize DNT.
4. How does TradeWing protect personal information?
Where applicable, TradeWing uses industry-standard technology in connection with the Client Services and the Site to help protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
5. How long does TradeWing retain my personal information?
Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided for under services contracts with clients or as required or authorized by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or de-identified.
6. What are my choices concerning my personal information?
Our clients are responsible for notification of purpose and for obtaining appropriate consent, to the extent required by law, when they collect personal information that is transferred to TradeWing.
Our clients are responsible for ensuring that any commercial emails sent by them comply with applicable law. If we are instructed by our clients to transmit communications on their behalf, clients remain responsible for ensuring that recipients have consented to receiving such communications and that the information contained in the communications are accurate and complete.
We do not sell, rent, or share the personal information of our users with third parties for such third parties’ own marketing purposes.
TradeWing may, subject to applicable laws, use personal information from our users to contact them about the Site and Client Services, including to provide them with information on additional products from TradeWing that may be of interest to them. Our users may exercise choices regarding these communications as follows:
- Mail marketing, Telephone marketing, Surveys and Quality control communications. You may decide that you prefer TradeWing not to use your personal information to promote new and/or additional products and/or services which may be of interest to you and refuse that we contact you by mail or telephone for marketing purposes or by email or telephone for quality control purposes. If this is the case, you may advise us by contacting customer service or contacting us using the information detailed in the Contacting us section below.
- Emails/Commercial Electronic Communications. You can always limit the communications that TradeWing sends to you. To opt-out of commercial emails, simply click the link labeled “unsubscribe” or “opt-out” at the bottom of any commercial electronic communication we send you. Please note that even if you opt-out of promotional communications, we may still need to contact you with important information about your account.
7. How is this Privacy Policy enforced?
TradeWing has put in place mechanisms to monitor and verify our ongoing adherence to this Privacy Policy. We encourage individuals covered by this Privacy Policy to raise any concerns that they have about the way that we process their personal information by contacting TradeWing as described below. We take your questions and concerns seriously, and we will use commercially reasonable efforts to resolve them.
8. What is TradeWing’s policy on kids’ privacy?
TradeWing and the Site and Client Services are not directed toward children and we do not knowingly solicit or collect personal information online from children under the age of 13 without prior verifiable parental consent. If TradeWing learns that a child under the age of 13 has submitted personal information online without parental consent, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information we have collected from children under age 13, please contact us using the information detailed in the Contacting Us section below.
9. Access, objection, deletion and correction
In certain jurisdictions, you may have the right to obtain confirmation as to whether your personal information is being processed, information about the purposes of that processing, and information about the recipients to whom your personal data have been or will be disclosed. You may also have the right to receive a copy of the personal data you have provided and/or request its deletion.
Our clients are responsible for managing any request made by their users regarding access to and rectification of their personal information that is transferred to us. However, if you have questions about your rights, please feel free to contact using the contact information detailed in the Contacting Us section below.
10. Your California Privacy Rights
If you are a California resident, California law provides you with the following rights with respect to your personal information:
- The right to know what personal information we have collected, used, disclosed and sold about you. You may submit a request to know by using the information detailed in the Contacting us section below. You also may designate an authorized agent to make a request for access on your behalf.
- The right to request that we delete any personal information we have collected about you. You may submit a request for deletion by using the information detailed in the Contacting us section below. You also may designate an authorized agent to make a request for deletion on your behalf.
When you exercise these rights and submit a request to us, we may verify your identity. We also may use a third party verification provider to verify your identity. Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.
For the 12-month period prior to the date of this Privacy Policy, we have not sold any personal information about our users; nor do we have any plans to do so in the future.
11. Transfer of personal information to other countries
In some cases, personal information that we process, including information from our users located in various countries, including in Canada, the EU and Switzerland or relative to queries or visitors to the Site may be transferred to the United States or other countries that may not have data privacy laws that provide the same protection as the countries where you reside. You understand that your personal information may therefore be transferred, processed and stored outside of your country of residence, and therefore may be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions.
12. Right to lodge complaints
We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or in the United States. For information on how you can file a privacy complaint with the Federal Trade Commission, please visit: https://www.ftccomplaintassistant.gov/
13. Changes to this Privacy Policy
TradeWing will review and update its Privacy Policy as required to keep current with rules and regulations, new technologies and security standards. We will post those changes on the Site and/or update the Privacy Policy modification date below. In certain cases and if the changes are material, we will provide written notice to clients directly by email or otherwise.
This Privacy Policy is effective as of January 1, 2020.
14. Contacting us
If there are any questions regarding this Privacy Policy or to request a copy of this Privacy Policy in another format, you may contact us using the information below.
TradeWing
Attn: Eric Meisel CEO
48 Grattan Street
San Francisco, CA 94117