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Data Processing Agreement

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Last Updated: 10.11.2025

This Data Processing Addendum (“DPA”) forms part of the Terms and Conditions and/or Privacy Policy of Trading Hedge Strategy (“Company”, “we”, “us”, “our”) and applies to the processing of Personal Data in connection with our website and services available at:

https://tradinghedgestrategy.com (the “Website”).

This DPA is intended to meet the requirements of applicable data protection laws, including the EU General Data Protection Regulation (GDPR).

1. Definitions

For the purposes of this DPA:

  • “Personal Data” means any information relating to an identified or identifiable natural person.

  • “Processing” means any operation performed on Personal Data, such as collection, storage, use, disclosure, or deletion.

  • “Controller” means the entity that determines the purposes and means of Processing Personal Data.

  • “Processor” means the entity that processes Personal Data on behalf of the Controller.

2. Roles of the Parties

For the Personal Data processed through our Website:

  • Trading Hedge Strategy acts as the Data Controller, determining why and how Personal Data is processed.

  • Third-party service providers may act as Data Processors, processing data only on our instructions and for the purposes described in this DPA.

3. Scope and Purpose of Processing

We collect and process Personal Data for the following purposes:

  • Providing access to digital content (including ebooks and downloads)

  • Sending transactional emails (such as delivery of download links)

  • Responding to customer inquiries and support requests

  • Website security and performance monitoring

  • Analytics and service improvement

  • Preventing fraud, abuse, or unauthorized access

4. Types of Personal Data Processed

Depending on user actions, we may process:

  • Name (if provided)

  • Email address

  • IP address

  • Device and browser data

  • Website interaction data (pages visited, time spent, referrer)

  • Purchase-related details (when applicable)

  • Support messages and communication history

We do not intentionally collect sensitive personal data (such as health data, biometric data, or political opinions).

5. Categories of Data Subjects

Personal Data may relate to:

  • Website visitors

  • Customers and users requesting digital downloads

  • Individuals contacting our support team

6. Data Processing Instructions

Our Processors are authorized to process Personal Data only:

  • to provide services requested by us, and

  • in accordance with written instructions described in this DPA and our Privacy Policy.

7. Confidentiality

We ensure that persons authorized to process Personal Data are bound by confidentiality obligations and access data only when necessary for service delivery.

8. Security Measures

We implement appropriate technical and organizational measures designed to protect Personal Data, including:

  • encryption (where applicable)

  • access control and authentication measures

  • server security and monitoring

  • regular updates and patching of software

  • backups and recovery procedures

No method of transmission over the internet is 100% secure; however, we take reasonable measures to reduce risk.

9. Subprocessors (Third-Party Providers)

We may use subprocessors (third-party service providers) to support our services, such as:

  • website hosting and server infrastructure providers

  • email delivery systems (SMTP providers)

  • analytics and performance tools

  • payment processors (if applicable)

These providers may process Personal Data only for the purposes required to deliver their services.

10. International Data Transfers

Where Personal Data is transferred outside the European Economic Area (EEA), we take steps to ensure appropriate safeguards are in place, such as:

  • EU Standard Contractual Clauses (SCCs), where applicable, or

  • other recognized legal transfer mechanisms under GDPR.

11. Data Retention

We keep Personal Data only for as long as necessary to:

  • provide the requested services

  • comply with legal obligations

  • resolve disputes and enforce agreements

  • maintain security and prevent abuse

Retention periods may vary depending on the type of data and purpose of processing.

12. Data Subject Rights

Individuals may have rights under GDPR and other data protection laws, including:

  • the right to access their Personal Data

  • the right to rectify inaccurate information

  • the right to erase Personal Data (“right to be forgotten”)

  • the right to restrict processing

  • the right to object to processing

  • the right to data portability (where applicable)

Requests can be submitted using the contact details below.

13. Assistance with Requests and Compliance

We take reasonable steps to:

  • respond to data subject requests within required timeframes

  • assist with privacy compliance where required

  • cooperate with competent supervisory authorities if necessary

14. Data Breach Notification

In the event of a personal data breach that may pose a risk to individuals, we will take reasonable steps to:

  • investigate and contain the incident

  • notify affected users when required by law

  • comply with any legal reporting obligations

15. Contact Information

For questions about this DPA or Personal Data processing, contact us at:

Trading Hedge Strategy

Email: support@tradinghedgestrategy.com
Website: https://tradinghedgestrategy.com/
Support: https://tradinghedgestrategy.com/contact-us/

16. Changes to This DPA

We may update this DPA from time to time to reflect legal, technical, or operational changes. The updated version will be posted on this page with the revised “Last updated” date.