Privacy Policy

Privacy Policy

TDA Services GmbH Privacy Policy

Our Privacy Policy was last updated on the 20th October 2020
This Privacy Policy (“Privacy Policy”) describes how TDA Services GmbH (“TDA” referred to as “we,” “us” or “our”) handle your personal data, as well as the kinds of personal data we collect about you, how your personal data could be used and when it might be disclosed, how we protect your personal data and the rights you have relating to the processing of your personal data. TDA respects your privacy and we commit to protecting your personal data in accordance with relevant data privacy laws and our internal policies. 
This Privacy Policy applies to personal information collected by us through our website at traderdefenseadvisory.com as well as any other related sites and applications. The Privacy Policy also applies to personal information that we collect when you use or interact with our services through any correspondence with us by phone, e-mail, etc. It also applies in other cases of our data processing where no other privacy policy or notice applies, for example regarding our partners. The Privacy Policy does not apply to websites operated by other organizations or third parties.
We reserve the right to alter the details of the Privacy Policy from time to time and you are, therefore, advised to check it frequently. 

Your Information

When you enter personal information on TDA forms, we encrypt the whole transmission using Secure Socket Layer (SSL) technology.

Your personal information is stored behind secured networks and is only accessible by a limited number of people who have special access rights to such systems and are required to keep your information confidential.  Your information is required to permit us to fulfill the terms of our contract.  It may also be used to send you promotional materials or communications regarding our services if we believe they may be of interest to you.  We may also contact you to request feedback on services we provided you or for market or other research purposes.

You may request at any time that we stop sending you emails or other communication by sending a message from your registered email address to __ with “unsubscribe” in the subject line.

We use various of security measures when users enter, submit or access their information to keep it safe and confidential.

1. Who Is the Controller of My Personal Data?

Unless we alert you otherwise, TDA controls your personal data and it alone or jointly determines how or why your personal data is processed. One of our affiliated entities may process your personal data under certain conditions, depending on our relationship and the services we are providing to you. 

2. How Do We Collect Your Personal Data?

We use various methods to collect personal data from and about you, including:

Collection directly from you

Most of your personal data that we process comes directly from you. You might, for example, give us your name and contact details when filling out forms or corresponding with us by email, phone, mail, in person, etc., such as when you:

Automatic collection

We automatically collect technical data when you use our websites, for example: IP address, log-in data, browser type, time zone setting and location and plug-in types when you interact with our websites. We additionally collect data through cookies. 

A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain data such as a user ID that the site uses to track the pages you have visited. We use Facebook Pixel and Google Analytics cookies subject to your consent.

Our website, traderdefenseadvisory.com, may place and/or store other types of information (e.g., “cookies” as defined above) on your computer. We use these cookies to improve your experience on our website. We do not place any private information in these cookies and they may be removed at any time.

We ask for your consent to place the cookies, except for necessary ones, which enable the website to function properly.

You may decide to disable the cookies. However, you may not be able to access some parts of this website if you decide to disable the cookie acceptance in your browser, particularly the secure parts of the website.

For more information about cookies and how to disable them, please see http://www.allaboutcookies.org

You can choose to set your computer to warn you each time a cookie is being sent, or you can choose to disable all cookies. You do this through your browser (such as Microsoft Edge or Google Chrome) settings. Each browser has its own procedures, so see your browser’s Help menu to find the right way to modify your cookie settings.

If you disable your cookies, some features will also be disabled. That will not alter the user experience that makes your visit to our site more efficient but some of our services will not operate correctly.

Collection from other sources

If needed to prevent fraud or to manage our partners’ databases, we may collect information about you from third parties and public sources (including public databases and social media websites). This is to make sure that we have accurate, up to date, or required information for us to communicate with you or to give the best service possible. The kinds of information we may collect include personal details (including name, age, gender, and other demographic data) and contact information (including mailing address and phone numbers).

3. For What Uses and on What Legal Basis Do We Process Your Personal Data?

We have prepared below a description of all the ways we plan to use your personal data and on what legal basis we rely to do so. We have also specified what our legitimate interests are, where relevant.

If you disable your cookies, some features will also be disabled. That will not alter the user experience that makes your visit to our site more efficient but some of our services will not operate correctly.

Legal basis Purpose
Required for the compliance with a legal obligation which we are subject to.  Compliance with legal requirements. Managing our contractual relationship with you.
Required to perform a contract to which you are a party. To help you resolve your financial dispute.
Justified based on our legitimate interest to ensure the proper functioning of our business operations. To operate and manage our business operations and/or improve our products, service and client experience. To prevent fraud. To manage partners’ and suppliers’ databases and relationships.
Justified based on our legitimate interest to ensure that we can conduct and increase our business. Marketing to or communicating with you related to our products and services, according to the rules for direct marketing, described below in Section 4 (“How Do We Use Personal Data for Direct Marketing Purposes?”). We may also share personal data with our affiliates for this purpose, as described in Section 7 below, according to proportionality and appropriate international transfer mechanisms, notably Standard Contract Clauses.
Justified based on our legitimate interest to ensure we can conduct and increase our business and those of our business partners. If you are neither an EU citizen nor resident, sharing personal data with selected partners (including sponsors) by our non-EU affiliates, as described below in Section 6.
Justified based on our legitimate interest to ensure network and information security. Monitoring your use of our systems (for which purpose we may use technical tools to automatically monitor the use of our website and any apps or tools you use).
Justified based on our legitimate interest to ensure that you receive an excellent user experience. Improving the security and functionality of our website, networks and information.
Justified based on our legitimate interest in ensuring the correct functioning of our business operations. Undertaking data analytics by applying analytics to business operations and data to describe, forecast and improve business performance within TDA and/or to improve the user experience. (More details on how we operate analytics on our website can be seen in our cookie policy described in Section 2 above.)

4. How Do We Use Personal Data for Direct Marketing Purposes?

We may send you marketing communications to update you with our products and services, including those we believe may be of interest to you.

Do we send targeted e-mails?

We send targeted electronic direct marketing to business contacts at our clients or other companies with whom we want to develop or maintain a business relationship in compliance with relevant laws. Our electronic direct marketing normally includes web beacons, cookies, and similar technologies that inform us whether you open, read, or delete the message, and which links you click, if any. When you click a link in an electronic direct marketing message, we will also use a cookie to log what pages you view and what content you download from our websites, whether or not you are registered at or signed into our site. Please see our cookies policy for complete details.

Do we maintain Customer Relationship Management (CRM) databases?

Like most companies, TDA uses customer relationship management (CRM) database technology to operate and track our marketing efforts. Our CRM databases include personal data pertaining to business contacts at our clients and other companies with whom we either have an existing business relationship or wish to develop one. The personal information we use for these ends include pertinent business data such as: contact information, publicly available data (e.g. board membership, published articles, press releases, your public posts on social media sites if they pertain to the business purpose), your responses to previous targeted electronic direct marketing (including web activity related to links from our e-mails), website activity of registered users of our website and other business data included by TDA professionals based on their personal interactions with you.

Do we combine and analyze personal information?

We may combine information from publicly available sources, and from our various e-mail, website, and personal interactions with you (this includes data collected across our different websites such as our careers and corporate sites and data collected when you sign-up or log on to our sites or connect to our sites using your social media credentials). We combine this information to better understand your experience with TDA and to engage in the other activities described throughout this Privacy Policy.

What are your rights regarding marketing communications?

You can choose to not receive marketing communications from us by using opt-out mechanisms in e-mails you receive from us or on our website when you enter your email. You can also decline to receive marketing communications or request that your personal data be deleted from our CRM databases by contacting our Data Protection Officer at __.

5. What about Sensitive Data?

We do not typically try to collect sensitive data (also known as special categories of personal data) from individuals and we ask that you please do not submit sensitive data to us. In the limited cases where we do seek to collect such data, we will do this in compliance with data privacy law requirements and/or we will request your consent.

The term “special categories of data” can refers to various categories of personal information including racial or ethnic origin, political opinions, religious, philosophical, or other such beliefs, membership in a trade union, physical or mental wellbeing, biometric or genetic data, sexual life or orientation, or criminal convictions and offences (including data regarding suspected criminal activities).

6. What about Persons Under 18 Years of Age?

We are concerned about protecting the privacy of children. We do not knowingly contact or collect information from persons under the age of 18. Our website is not intended to request any kind of information from persons under the age of 18.

If you believe that we have received information regarding or from persons under the age of 18 please contact us at __. If we are made aware that a person under the age of 18 has given us personal information, we will take steps to delete it.

7. Will We Share Your Personal Information with Third Parties?

We may share personal information with the following categories of recipients:

We may also share your personal information with public and governmental authorities if we are required to do so, or with third parties regarding potential corporate or commercial transactions.

Before we share your personal information with any third party, such as trusted suppliers, business partners, advertisers, and search engines, we will take the required actions to ensure that your personal information will be given necessary protection in compliance with relevant data privacy laws and TDA internal policies.

8. How Long Will Your Personal Data Be Retained by Us?

We keep your data for no longer than needed for the purpose for which we collected it. Our dispute related information is normally kept for seven (7) years. We apply specific records management and retention policies and procedures, so that in deciding how long your data will be kept, we will consider:

9. Do We Transfer Your Data Internationally?

Since we are a global organization present in a number of jurisdictions and countries, we may transfer your personal information to our affiliates in other countries. If you are located within the EEA, this may involve transferring your data outside the EEA. To ensure that such transfers are in compliance with relevant laws and carefully handled to protect your privacy rights, any inter-company transfers of personal data are covered by agreement(s) which contractually require(s) us to ensure adequate and consistent levels of protection wherever personal information is transferred within our group of companies. We may also share your personal information with third parties (see Section 7), some of which are based outside the EEA. Whenever we transfer your personal information outside the EEA, we ensure a similar degree of protection is provided it by ensuring relevant safeguards are undertaken. For example, we may use certain contracts approved by the European Commission. Please communicate with us (see our details at section 11 below) if you would like more information on the procedures used by us when transferring your personal data outside the EEA.

10. Data Security

We operate organizational, physical and technical security procedures for all the personal information we hold. We have protocols, controls and applicable policies, procedures and guidance to maintain these arrangements taking into account the risks associated with various categories of personal information and the processing we undertake. These procedures may include, as appropriate:

11. What are Your Rights Regarding the Processing of Your Personal Data?

If you are located within the EEA, you may be entitled under certain circumstances to:

If you are located in CALIFORNIA you have many of the rights set out in this Section 11 and you are additionally entitled under certain circumstances to prohibit the sale of personal data and to request access to certain information about the personal data we have shared with third parties for the purpose of direct marketing.

Please email us at __ to utilize any of these rights. We will process all requests in accordance with relevant local laws and our policies and procedures. Before disclosing to you the information you request, we may ask you for additional information in order to confirm your identity and for security purposes.

12. What if You Have Questions or Want Additional Information?

TDA is the controller of your personal data and is registered as a data controller with the UK Information Commissioner’s Office under registration number __.

Any questions regarding this document and our privacy practices should be sent to our Data Protection Officer:

If you wish to make a complaint regarding how we use your information, please email us at __ and we will do our best to assist you. If you are located within the EEA, you have the right to file a complaint with the appropriate data protection supervisory authority in your country. We would, however, appreciate the opportunity to deal with your concerns before you approach your local supervisory authority. We would therefore appreciate if you contact us first.