PRIVACY POLICY

Privacy Statement

This Tradebuilder (hereafter TBC) Privacy Statement ("Privacy Statement") describes our privacy practices. Please read this Privacy Statement carefully to learn how we collect, use, share and otherwise process information relating to individuals ("Personal Data"), and your rights and choices regarding our processing of your Personal Data.

A reference to “Tradebuilder,” “TBC,” “IMK,” “IMKLOUD,” “we,” “us,” “our,” or the “Company” is a reference to Tradebuilder Corporation.

Processing activities covered

This Privacy Statement applies to the following processing activities:

  • Visiting our websites which display or link through to this Privacy Statement;
  • Visiting our offices;
  • Receiving communications from us, including emails, texts or fax;
  • Registering for our Seminars,Webinars, and/or events;
  • Participating in MaS (Marketing-as-Service”):
  • Participating in SaS (Software-as-Service”):
  • Participating in PaS (Platform-as-Service”)

Our websites may contain links to other websites, applications and services maintained by third parties. The information practices of such other services are governed by the third-party privacy statements, which we encourage you to review to better understand those third parties’ privacy practices.

What personal data we collect?

The Personal Data that we collect directly from you may include the following:

  • if you express an interest in obtaining additional information about our services, request customer support, use our "Contact Us" or similar features, register to use our websites, sign up for an event or webinar, or download certain content, we generally require you to provide us with your contact information, such as your name, job title, company name, address, phone number, email address, or username and password;
  • if you makes purchases via our websites or register for an event, we may also require you to provide us with financial information and billing information, such as billing name and address, credit card number, or bank account information;
  • if you attend an event, we may, upon your consent, scan your attendee badge which will provide us with your name, title and company name, address, country, phone number and email address;
  • if you register for an online community that we host, we may ask you to provide a username, photo and/or biographical information, such as your occupation, social media profiles, company name, and areas of expertise;
  • if you use and interact with our websites, we automatically collect log files and other information about your device and your usage of our websites through cookies, web beacons or similar technologies, such as IP-addresses or other identifiers, which may qualify as Personal Data (view the "What device and usage data we process" section below);
  • if you visit our offices, you may be required to register as a visitor and to provide your name, email address, phone number, company name and time and date of arrival.
Personal Data we collect from other sources

We may also collect information about you from other sources, including third parties from whom we have purchased Personal Data, and combine this information with Personal Data provided by you. This helps us to update, expand and analyze our records, identify new customers, and create more tailored advertising to provide services that may be of interest to you. In particular, we collect Personal Data from the following sources:

  • Business contact information, including mailing address, job title, email address, phone number, ‘intent data’ which is web user behavior data, IP addresses, social handles, LinkedIn URL and custom profiles from third party data providers for the purposes of targeted advertising, delivering relevant email content, event promotion and profiling;
  • Both TBC and IMK use platforms such as GitHub to manage code check-ins and pull requests. If you participate in PaS, we may associate your code repository username with your account in IMK so we could inform you of program changes that are important to your participation or additional security requirements.
Purposes for using information

In addition to the purposes mentioned above, we may use your information for the following purposes:

To communicate with you (such as through email) about products that you have downloaded and services that you have signed up for, changes to this Privacy Policy, changes to the Terms of Service, or important notices;

To keep you posted on new products and services, upcoming events, offers, promotions and other information that we think will be of interest to you;

To ask you to participate in surveys, or to solicit feedback on our products and services;

To set up and maintain your account, and to do all other things required for providing our services, such as enabling collaboration, providing website and mail hosting, and backing up and restoring your data;

To understand how users use our products and services, to monitor and prevent problems, and to improve our products and services;

To provide customer support, and to analyze and improve our interactions with customers;

To detect and prevent fraudulent transactions and other illegal activities, to report spam, and to protect the rights and interests of Tradebuilder, Tradebuilder’s users, third parties and the public;

To update, expand and analyze our records, identify new customers, and provide products and services that may be of interest to you;

To analyze trends, administer our websites, and track visitor navigations on our websites to understand what visitors are looking for and to better help them;

To monitor and improve marketing campaigns and make suggestions relevant to the user.

Legal bases for collecting and using information

Legal processing bases applicable to TBC: If you are an individual from the European Economic Area (EEA), our legal basis for information collection and use depends on the personal information concerned and the context in which we collect it.

Most of our information collection and processing activities are typically based on (i) contractual necessity, (ii) one or more legitimate interests of TBC or a third party that are not overridden by your data protection interests, or (iii) your consent. Sometimes, we may be legally required to collect your information, or may need your personal information to protect your vital interests or those of another person.

Withdrawal of consent : Where we rely on your consent as the legal basis, you have the right to withdraw your consent at any time, but this will not affect any processing that has already taken place.

Legitimate interests notice : Where we rely on legitimate interests as the legal basis and those legitimate interests are not specified above, we will clearly explain to you what those legitimate interests are at the time that we collect your information.

Your choice in information use

Opt out of non-essential electronic communications : You may opt out of receiving newsletters and other non-essential messages by using the ‘unsubscribe’ function included in all such messages. However, you will continue to receive notices and essential transactional emails. Disable cookies : You can disable browser cookies before visiting our websites. However, if you do so, you may not be able to use certain features of the websites properly.

Optional information : You can choose not to provide optional profile information such as your photo. You can also delete or change your optional profile information. You can always choose not to fill in non-mandatory fields when you submit any form linked to our websites. Who we share your information with

All TBC group entities listed here have access to the information covered in Part I. We do not sell any personal information. We share your information only in the ways that are described in this Privacy Policy, and only with parties who adopt appropriate confidentiality and security measures.

Employees and independent contractors

Employees and independent contractors of all TBC group entities have access to the information covered in Part I on a need-to-know basis. We require all employees and independent contractors of TBC group entities to follow this Privacy Policy for personal information that we share with them.

Third-party service providers : We may need to share your personal information and aggregated or de-identified information with third-party service providers that we engage, such as marketing and advertising partners, event organizers, web analytics providers and payment processors. These service providers are authorized to use your personal information only as necessary to provide these services to us.

Domain registrars

When you register a domain through TBC from domain name registrars, we share your name and contact information such as your physical address, email address and phone number with them as per the ICANN domain registration rules.

Reselling partners:

We may share your personal information with our authorized reselling partners in your region, solely for the purpose of contacting you about products that you have downloaded or services that you have signed up for. We will give you an option to opt out of continuing to work with that partner.

Platform as Service - PaS:

When you hire TBC to develop application using IMKLOUD APIs that is hosted on IMK’s online platform, your name and email address will be shared with the developer of the application, so they may engage with you directly as the provider of that application or service. IMK does not control the use of your personal information by the developers, which will be based on their own privacy policies.

Your rights with respect to information we hold about you as a controller. If you are in the European Economic Area (EEA), you have the following rights with respect to information that TBC holds about you. TBC undertakes to provide you the same rights no matter where you choose to live.

Right to access

You have the right to access (and obtain a copy of, if required) the categories of personal information that we hold about you, including the information's source, purpose and period of processing, and the persons to whom the information is shared

Right to rectification

You have the right to update the information we hold about you or to rectify any inaccuracies. Based on the purpose for which we use your information, you can instruct us to add supplemental information about you in our database. Right to erasure : You have the right to request that we delete your personal information in certain circumstances, such as when it is no longer necessary for the purpose for which it was originally collected.

Right to restriction of processing

You may also have the right to request to restrict the use of your information in certain circumstances, such as when you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Right to data portability

You have the right to transfer your information to a third party in a structured, commonly used and machine-readable format, in circumstances where the information is processed with your consent or by automated means.

Right to object : You have the right to object to the use of your information in certain circumstances, such as the use of your personal information for direct marketing. Right to complain : You have the right to complain to the appropriate supervisory authority if you have any grievance against the way we collect, use or share your information. This right may not be available to you if there is no supervisory authority dealing with data protection in your country.

Retention of information

We retain your personal information for as long as it is required for the purposes stated in this Privacy Policy. Sometimes, we may retain your information for longer periods as permitted or required by law, such as to maintain suppression lists, prevent abuse, if required in connection with a legal claim or proceeding, to enforce our agreements, for tax, accounting, or to comply with other legal obligations. When we no longer have a legitimate need to process your information, we will delete or anonymize your information from our active databases. We will also securely store the information and isolate it from further processing on backup discs until deletion is possible.

How do we use the information we collect?
Information entrusted to TBC and purpose

We treat your data as information that is private to you. Unless you decide to share your information and/or responses with the public, we do not use your data for our own purposes, except in the limited circumstances described in this privacy policy or unless we have your express consent. We do not sell your data to third parties.

This includes information regarding your customers and your employees (if you are a controller) or data that you hold and use on behalf of another person for a specific purpose, such as a customer to whom you provide services (if you are a processor). The data may either be stored on our servers when you use our services, or transferred or shared to us as part of a request for technical support or other services. We use the information we collect from you in connection with providing our services to you and, on your behalf, to your end clients.

Information from mobile devices : When you elect to allow it, some of our mobile applications have access to the camera, call history, contact information, photo library, and other information stored on your mobile device.

Our applications require such access to provide their services. Similarly, when you elect to provide access, location-based information is also collected for purposes including, but not limited to, locating nearby contacts or setting location-based reminders.

This information will be exclusively shared with our mapping providers and will be used only for mapping user locations. You may disable the mobile applications' access to this information at any time by editing the settings on your mobile device.

The data stored on your mobile device and their location information to which the mobile applications have access will be used in the context of the mobile application, and transferred to and associated with your account in the corresponding services (in which case the data will be stored on our servers) or products (in which case the data will remain with you unless you share it with us).

(All the information entrusted to TBC is collectively termed “service data”)
Ownership and control of your service data
We recognize that you own your service data. We provide you complete control of your service data by providing you the ability to (i) access your service data, (ii) share your service data through supported third-party integrations, and (iii) request export or deletion of your service data.

How we use service data

We process your service data when you provide us instructions through the various modules of our services. For example, when you generate an invoice, information such as the name and address of your customer will be used to generate the invoice; and when you use our campaign management service for email marketing, the email addresses of the persons on your mailing list will be used for sending the emails.

Push notifications

If you have enabled notification on our desktop and mobile applications, we will push notifications through a push notification provider such as Apple Push Notification Service, Google Cloud Messaging or Windows Push Notification Services. You can manage your push notification preferences or deactivate these notifications by turning off notifications in the application or device settings.

Who we share service data with

TBC group and third party sub-processors: In order to provide services and technical support for our products, the contracting entity within the TBC group engages other group entities and third parties .

Employees and independent contractors: We may provide access to your service data to our employees and individuals who are independent contractors of the TBC group entities involved in providing the services (collectively our “employees”) so that they can (i) identify, analyze and resolve errors, (ii) manually verify emails reported as spam to improve spam detection, or (iii) manually verify scanned images that you submit to us to verify the accuracy of optical character recognition. We ensure that access by our employees to your service data is restricted to specific individuals, and is logged and audited. Our employees will also have access to data that you knowingly share with us for technical support or to import data into our products or services. We communicate our privacy and security guidelines to our employees and strictly enforce privacy safeguards within the TBC group.

Collaborators and other users: Some of our products or services allow you to collaborate with other users or third parties. Initiating collaboration may enable other collaborators to view some or all of your profile information. For example, when you edit a document that you have shared with other persons for collaboration, your name and profile picture will be displayed next to your edits to allow your collaborators to know that you made those edits.

Third-party integrations you have enabled: Most of our products and services support integrations with third-party products and services. If you choose to enable any third-party integrations, you may be allowing the third party to access your service information and personal information about you. We encourage you to review the privacy practices of the third-party services and products before you enable integrations with them.

Other cases: Other scenarios in which we may share information that are common to information covered under Parts I and II are described in Part III.

Retention of information

We hold the data in your account as long as you choose to use TBC Services. Once you terminate your TBC user account, your data will eventually get deleted from active database during the next clean-up that occurs once in 6 months. The data deleted from active database will be deleted from backups after 3 months.

Data subject requests

If you are from the European Economic Area and you believe that we store, use or process your information on behalf of one of our customers, please contact the customer if you would like to access, rectify, erase, restrict or object to processing, or export your personal data. We will extend our support to our customer in responding to your request within a reasonable timeframe.

General

How secure is your information

At TBC, we take data security very seriously. We have taken steps to implement appropriate administrative, technical & physical safeguards to prevent unauthorized access, use, modification, disclosure or destruction of the information you entrust to us. If you have any concerns regarding the security of your data, we encourage you to check ourSecurity Policy or write to us at security@tradebuiderinc.com with any questions.

Data Sharing

Your information if there's a change in business ownership or structure. If ownership of all or substantially all of our business changes, or we undertake a corporate reorganization (including a merger or consolidation) or any other action or transfer between TBCr entities, you expressly consent to TBC transferring your information to the new owner or successor entity so that we can continue providing our services. If required, TBC will notify the applicable data protection agency in each jurisdiction of such a transfer in accordance with the notification procedures under applicable data protection laws.

We share your personal information and service data within the TBC Group. By accessing or using our products and services or otherwise providing personal information or service data to us, you consent to the processing, transfer, and storage of your personal information or Service Data within the United States of America, the European Economic Area (EEA) and other countries where TBC operates. Such transfer is subject to a group company agreement that is based on EU Commission’s Model Contractual Clauses.

Data processing addendum

To enable you to be compliant with the data protection obligations under the General Data Protection Regulation, we are prepared to sign a Data Processing Addendum (DPA) that is based on Standard Contractual Clauses. You can request a DPA from TBC by completing this form . Once we get your request, we'll forward the DPA to you for your signature.

Do Not Track (DNT) requests

Some internet browsers have enabled 'Do Not Track' (DNT) features, which send out a signal (called the DNT signal) to the websites that you visit indicating that you don't wish to be tracked. Currently, there is no standard that governs what websites can or should do when they receive these signals. For now, we do not take action in response to these signals.

External links on our websites

Some pages of our websites may contain links to websites that are not linked to this Privacy Policy.
If you submit your personal information to any of these third-party sites, your personal information is governed by their privacy policies. As a safety measure, we recommend that you not share any personal information with these third parties unless you've checked their privacy policies and assured yourself of their privacy practices.

Blogs and forums

We offer publicly accessible blogs and forums on our websites. Please be aware that any information you provide on these blogs and forums may be used to contact you with unsolicited messages. We urge you to be cautious in disclosing personal information in our blogs and forums. TBC is not responsible for the personal information you elect to disclose publicly. Your posts and certain profile information may remain even after you terminate your account with TBC. To request the removal of your information from our blogs and forums, you can contact us at privacy@tradebuilderinc.com

Social media widgets

Our websites include social media widgets such as Facebook "like" buttons and Twitter "tweet" buttons that let you share articles and other information. These widgets may collect information such as your IP address and the pages you navigate in the website, and may set a cookie to enable the widgets to function properly. Your interactions with these widgets are governed by the privacy policies of the companies providing them.

Disclosures in compliance with legal obligations
We may be required by law to preserve or disclose your personal information and service data to comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements. Enforcement of our rights

We may disclose personal information and service data to a third party if we believe that such disclosure is necessary for preventing fraud, investigating any suspected illegal activity, enforcing our agreements or policies, or protecting the safety of our users.

Business Transfers

We do not intend to sell our business. However, in the unlikely event that we sell our business or get acquired or merged, we will ensure that the acquiring entity is legally bound to honor our commitments to you. We will notify you via email or through a prominent notice on our website of any change in ownership or in the uses of your personal information and service data. We will also notify you about any choices you may have regarding your personal information and service data.

Compliance with this Privacy Policy

We make every effort, including periodic reviews, to ensure that personal information you provide is used in conformity with this Privacy Policy. If you have any concerns about our adherence to this Privacy Policy or the manner in which your personal information is used, kindly write to us privacy@tradebuilderinc.com We'll contact you, and if required, coordinate with the appropriate regulatory authorities to effectively address your concerns.

Notification of changes

We may modify the Privacy Policy at any time, upon notifying you through a service announcement or by sending an email to your primary email address. If we make significant changes to the Privacy Policy that affect your rights, you will be provided with at least 30 days' advance notice of the changes by email to your primary email address. If you think that the updated Privacy Policy affects your rights with respect to your use of our products or services, you may terminate your use by sending us an email within 30 days. Your continued use after the effective date of changes to the Privacy Policy will be deemed to be your agreement to the modified Privacy Policy. You will not receive email notification of minor changes to the Privacy Policy. If you are concerned about how your personal information is used, you should check back at periodically.

Consents

By signing up for an account, clicking "I Agree" or any other button indicating your acceptance of this privacy policy, you expressly consent to the following:

  • You consent to the collection, use, disclosure and processing of your personal data in the manner described in this privacy policy, including our procedures relating to cookies, IP addresses and log files.
  • We use Google Cloud Services to host your data, so your personal data will be primarily processed by us in the locations where Google offers its infrastructure.
  • You consent to us sharing your personal data with relevant persons working for service providers who assist us to provide our services.
  • If you have enabled cookies on your web browser, you consent to our use of cookies as described in this privacy policy.

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