Our Privacy Policy

Privacy Policy Updated 22 May 2018

1. INTRODUCTION AND GENERAL TERMS

This privacy statement is made on behalf of Simpler Markets Limited (referred to as “SML”, “We”, “Us” or “the Company”) trading as LeadingTrader.

Simpler Markets Limited (“SML”) is an education company and offers a range of content, products and services related to learning about chart analysis. We are committed to respecting your privacy and keeping your information safe. We want to give you clear information about what information we collect and how we use it. We are committed to respecting your privacy and keeping your personal information. This privacy and cookies policy tells you what to expect when SML collects personal information. This privacy and cookies policy relates to our use of personal information we collect from you via the following:

  • Simpler Markets Limited Websites and Landing Pages (including leadingtrader.com)
  • Any 3rd party marketing referrals

Acknowledgment and Acceptance of Terms

The Company is committed to protecting your privacy. This Privacy Policy sets forth our current privacy practices with regard to the information we collect when you or your computer or mobile device interacts with our website. By accessing this website (the “Site”), you agree with and consent to the terms of this Privacy Policy.

2. WHO WE ARE

This privacy notice applies to the use of personal information by SML. Each entity which collects or receives your data under the privacy notice does so as a data controller. Any member of SML may use and share within the group, the information you provide and other information it holds about you for the purposes set out in the privacy notice, applying appropriate security measures to keep your information safe and secure.

3. WHAT PERSONAL INFORMATION WE COLLECT ABOUT YOU

We collect personal information about you. We may collect this information when you:

  • When you register for our emails
  • Register for a webinar
  • When you attend a seminar
  • When you purchase a SML Education Product
  • When you purchase a SML Product such as chart indicators
  • Sign up for publications, videos, webinars or newsletters
  • Sign up to become a member in our LeadingTrader Membership service
  • Sign up to become a member of any other related educational program.
  • Telephone, write, contact us online or text us or otherwise provide us with your personal information

This can include information such as Your name, email address, postal address, IP address, telephone number, mobile number, Payment details, order details, products ordered, date subscribed.

We only collect sensitive personal information if we are under a legal obligation to do so, for example, relating to your health if you request special assistance for an event. Any such information is securely stored on your delegate or subscriber profile.

Payment Data

We collect information from you when purchasing a Membership, seminar or software (as defined in the Terms and Conditions). When a purchase is made, your credit or debit card information (such as card number, type and expiration date) and other financial data needed to process your payment will be collected and stored by us and/or the payment processors with which we work.

Third-Party Sites

The Site may contain links to other websites, or you may have been linked to this Site from another website, but this Privacy Policy does not apply to those external sites and we are not responsible for their content. If you visit external websites, we recommend that you review their privacy policies. If we materially change our privacy policies or practices, we will also amend this Privacy Policy to reflect such change. You should review the Privacy Policy each time you access the Site.

4. HOW WE USE YOUR INFORMATION

We will not rent, swap or sell your personal information to other organisations for them to use in their own marketing activities without your consent.

The legal basis that we rely on for processing your data will depend upon the circumstances in which it is being collected and used, but will in most cases fall into one of the following categories:

  • Where you have taken clear affirmative action and consent is implied. For example, where you have provided your personal data via an online form.
  • Where you have provided your consent to allow us to use your data in a certain way
  • Where the processing is necessary to carry out the performance of a contract with you; for example, if you purchase a product or service from us we would need to process your information to enable us to supply the product or service
  • Where the processing is necessary for us to comply with a legal obligation; or
  • Where it is in our legitimate interests to perform our functions; for example, we may share your data with our IT department and administrators because to get the most benefit from your experience with SML it is necessary and a benefit for you so that you can gain access to the services you have registered for. It is in our interest to ensure our customers and subscribers have the best possible service and experience, and therefore we deem it in our legitimate interests to share this information.

If you have given your consent, we will use your information for a number of purposes including the following:

  • To collect personal information about you, your interests and likes
  • Send you information regarding the specific service you have paid for.
  • Send you information regarding the webinar, video or newsletter you have registered for.
  • Send information on other products and services of SML including our Membership, chart indicators, educational programs and webinars.
  • Send you information relating to events that SML is involved in.

5. INTERNATIONAL TRANSFERS

The information that we collect from you may be transferred to, and stored at, a destination outside of the European Economic Area (“EEA”). It may also be processed by staff in destinations outside the EEA who work for us or for one of our third party service providers.

These destinations may not have the same legal protections for personal data as you enjoy under English law. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy statement and data protection legislation.

When we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

  • the countries we transfer your personal data to have been deemed to provide an adequate level of protection for personal data by the European Commission;
  • we use contractual clauses approved by the European Commission which give personal data similar protection to that which it has in the EEA; or
  • where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data that applies within the EEA.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the EEA.

6. OTHER WAYS WE USE YOUR INFORMATION

We may carry out analysis of the information we collect about you to optimise the products and services we provide.

We may use the information we collect from you when you register, sign up for a Membership, or otherwise enter information on the site in the following ways:

* To quickly process your transactions
* To ensure products are delivered to you
* To provide offers, information and other products to you

We do not rent, sell or share your personal information or personalized data to unaffiliated organizations except to provide the products or services you have requested, when we have your permission, or when required by applicable law or regulation. The Site also gives users the option for removing their information from our database in order to stop receiving our communications.

We may also use your data to find similar profiles of person using marketing tools within Google. Your data will be stored within the SML Google accounts, however your information cannot be accessed by Google.

HOW DO WE PROTECT YOUR INFORMATION?

To protect your personal information, we take reasonable precautions and follow industry best practices to make sure it is not inappropriately lost, misused, accessed, disclosed, altered or destroyed.

Our website is hosted by Bluehost.com and information is processed in compliance with their privacy policy. Bluehost.com employs security measures such as using firewalls to protect against intruders, building redundancies throughout their network (so that if one server goes down, another can cover for it) and testing for and protecting against network vulnerabilities. For more information on how Bluehost.com processes and protects information, review their Privacy Policy (https://www.bluehost.com/terms/privacy-policy).

In addition, your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems, and are required to keep the information confidential.

When you initially provide or update your payment information, we transmit it via an encrypted connection to our Payment Processor, PayPal. PayPal uses and processes your payment information in accordance with PayPal’s Privacy Policy ( https:/www.paypal.com/en/webapps/mpp/ua/privacy-full ). By accessing our site and purchasing services, you agree to PayPal’s privacy policy.

In the processing of payments, we also engage additional third-party service providers, each of which has their own privacy policy (below). By accessing our site and purchasing services, you agree to their privacy policies:

1automationwiz.com ( https://www.1automationwiz.com/privacy-policy.html )
trepstar.com for DVD/USB shipments ( https://www.trepstar.com/privacy-spam-policy.asp )

We don’t store your payment information, other than your zip code and country, which we require for billing and to comply with tax and other government regulations. All sensitive and credit information you supply is encrypted via Secure Socket Layer (SSL) technology.

You always have the right to request Company delete or correct the information held about you. If you wish to alter, access or remove content please contact us at data@leadingtrader.com.

Other third-party service providers

We also use other third-party service providers to communicate with customers and site users. These third-party service providers have their own privacy policies. By accessing our site, you agree to their privacy policies:

Aweber ( https://www.aweber.com/privacy.htm )
Zoho Mail ( https://www.zoho.com/privacy.html )
InfusionSoft ( https://www.infusionsoft.com/legal/privacy-policy )
GotoWebinar ( https://www.logmeininc.com/legal/privacy )

Third-party disclosure

We do not sell, trade or otherwise transfer to outside parties your personally identifiable information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it’s release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising or other users.

In addition, we may disclose your information in connection with conducting our business. In the event Company is involved in a business transition that involves the sale, merger or divestment of Company, we may disclose any information about you to the acquiring entities. This transferred information will remain subject to the provisions of this Privacy Policy, as updated.

7. WILL I BE CONTACTED FOR MARKETING PURPOSES

SML will only send you marketing emails where you have consented to this and you are able to withdraw your consent at any time by updating your preferences or by contacting us on: data@leadingtrader.com.

8. WILL MY INFORMATION BE SHARED WITH ANYONE ELSE

Third-party disclosure

We do not sell, trade or otherwise transfer to outside parties your personally identifiable information unless we provide users with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or serving our users, so long as those parties agree to keep this information confidential. We may also release information when it’s release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property or safety. However, non-personally identifiable visitor information may be provided to other parties for marketing, advertising or other users.

In addition, we may disclose your information in connection with conducting our business. In the event Company is involved in a business transition that involves the sale, merger or divestment of Company, we may disclose any information about you to the acquiring entities. This transferred information will remain subject to the provisions of this Privacy Policy, as updated.

9. HOW LONG WILL SML KEEP MY INFORMATION?

We will hold your personal information on our systems for as long as is necessary for the relevant activity or until you request that we remove your information from our systems via our Telling Us When Things Change section.

Your information will generally not be held for more than 7 years from the time of your last interaction with us.

10. TELLING US WHEN THINGS CHANGE

You can help us keep our records up to date by telling us when your contact details and other personal information changes. You can also change your mind at any time about how we contact you or ask us to stop contacting you altogether.

Please contact: data@leadingtrader.com 

11. CAN I FIND OUT WHAT PERSONAL INFORMATION SML HOLDS ABOUT ME

You have the right to request a copy of the personal information we hold about you and to have any inaccuracies corrected. We require you to prove your identity with 2 pieces of approved identification. We will provide you with the information within 1 month of your request unless requests are complex and numerous.

Your Rights

You have the right to request access to personal data that we may process about you. If you wish to exercise this right, you should contact us at data@leadingtrader.com.

You have the right to require us to correct any inaccuracies in your personal data free of charge. If you wish to exercise this right, you should contact us using the details referred to above and specify the information that is incorrect and what it should be replaced with.

In certain circumstances you have the right to require us to erase personal data that we may process about you. If you wish to exercise this right, you should contact us using the details referred to above although please note that we may be required to retain some or all of your personal information.

If you have any concerns or questions as to the way in which we process your information please do contact us. In addition, you have a right to bring a complaint with the Information Commissioner’s Office. More information on the Information Commissioner’s Office and your rights is available at www.ico.org.uk or on 0303 123 1113.

For any requests in respect of your data please contact data@leadingtrader.com 

12. COOKIES – PRIVACY POLICY

A cookie is a small amount of data, which often includes a unique identifier that is sent to your computer, tablet or mobile phone (all referred to here as a “device”) web browser from a website’s computer and is stored on your device’s hard drive. Each website can send its own cookie to your web browser if your browser’s preferences allow it. Many websites do this whenever a user visits their website to track online traffic flows. Similar technologies are also often used within emails to understand whether the email has been read or if any links have been clicked.

We may use cookies to personalize or enhance your user experience. Cookies are small pieces of text sent to your browser when you visit a site. They serve a variety of functions, like enabling us to remember certain information you provide to us as you navigate between pages on the Site. We use cookies to authenticate, personalize and secure your account as well as for analyze performance and analytics. If you reject cookies by changing your browser settings then be aware that this may disable some of the functionality on our Site.

WHAT CAN I DO ABOUT COOKIES?

You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies (Such as restricting third party cookies for instance).

However, if you use your browser settings to block all cookies (including essential cookies) you may not be able to access all or parts of the site and the functionality of the site may be impaired.

Except for essential cookies, all cookies will only be retained for a commercially reasonable period.

Do Not Track Signals

Do not track is a technology that enables users to opt out of tracking by websites they do not visit, including analytic services, advertising networks and social platforms. Our site uses information, which does not identify individual users, to analyze trends, to administer websites, to track user’s movements around websites, and to gather demographic information about our user base as a whole. We do not link this automatically-collected data to personally identifiable information. We do not currently support recognition of Do Not Track protocol. Users of this site should anticipate that data regarding their visit to this site is collected and used in the aggregate as mentioned earlier in this paragraph.

Google

Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users (https://support.google.com/adwordspolicy/ ). We have not enabled Google AdSense on the Site, but we may do so in the future.

Changes to this Statement

SML has the discretion to update this Privacy Statement at any time. When we do, we will also revise the “updated” date at the top of this page. We encourage you to review this Privacy Statement each time you access this site to stay informed about our use of your information. Access or use of the site is subject to the current version of the Privacy Statement.

California Online Privacy Protection Act

CalOPPA is the first state law in the nation to require commercial websites and online services to post a privacy policy. Compliance of the law is required by any company that reaches California consumers. According to CalOPPA, we agree to the following:

* You may visit our site anonymously

* We will add a link of the privacy policy on our home page

* You will be notified of any privacy policy changes on our privacy policy page, through the “updated date” on the top of the page

* You can change your personal information by emailing us at data@leadingtrader.com

Contact Information

If there are any questions regarding this privacy policy, you may contact us at data@leadingtrader.com.

REMEMBER AT ANY TIME YOU MAY CHANGE YOUR MIND ABOUT HOW WE CONTACT YOU OR ASK US TO STOP CONTACTING YOU ALL TOGETHER BY CONTACTING:

data@leadingtrader.com

For the SML internal privacy policy please click here.

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