Privacy Policy

I, Florian Köhler ("Trifortuna," "we," or "us"), hold a commitment to respecting your privacy and diligently strive to safeguard the confidentiality of the information you provide us. Your personal data will only be shared with third parties when essential for the provision of services and data you have specifically requested, as elaborated in detail within this privacy policy.

This privacy policy pertains to the personal data collected from you when you visit this Website, create an account, or utilize our applications or services ("you" or "your" being interpreted accordingly). It furnishes information on the nature of personal data we collect, the reasons for collecting such data, its utilization, the lawful basis for processing your personal data, the storage procedures, and the manner in which information is shared.

As employed in this privacy policy, "personal data" denotes any information that pertains to you and by which you can be identified.

By utilizing our Service or providing your personal data, you are expressing agreement to abide by the terms outlined in this privacy policy; therefore, we encourage you to read it attentively. In the event of disagreement with any aspect of this privacy policy, it is advisable to cease using our Services and proceed to delete your user account.

Updates

We retain the right to update this privacy policy at our discretion, periodically releasing a new version on our Website. It is recommended to regularly check our Website to ensure that any modifications align with your acceptance. In the case of substantial changes to the privacy policy, you will receive notifications as mandated by applicable law.

How do we collect information?

Individuals Conducting Searches

Account creation is not mandatory for users accessing specific market information, including tickers, prices, financial data, strategies, ideas, and publicly available data from Trifortuna users.

User Accounts

For users opting to create an account, the provision of specific personal data is required to access additional services for user benefit. You can also choose to provide additional information about yourself, as detailed below.

During registration, you will be prompted to provide:

Your username, email address, and a chosen password, or
If purchasing a subscription, your first name, last name, and postal address.

In certain cases, providing and verifying your phone number may be necessary. While additional information can be included in the profile settings, it is not mandatory.

Publicly Displayed Information

The following information will be publicly displayed:

Username
Profile picture
"About Me" section
Twitter handle
LinkedIn handle
Facebook handle
YouTube channel

Not Publicly Displayed Information:

The following information will not be publicly displayed:

Email address
Phone number
First name
Last name
Birthday
Company
Postal address, including street, city, state, and country

Contact Data

Furthermore, we process any personal data that you choose to provide during correspondence with us through phone, email, or any other means. This includes information obtained from visits and interactions with this Website or any other services we manage.

Cookies and other Technologies

We employ browser cookies (small text files placed on your device) to manage our Site, collect and analyze statistical information, ensure security, combat spam, and for advertising purposes. Cookies enhance your user experience while browsing our Website and contribute to the improvement of its features. Further details regarding the use of cookies can be found in our Cookies Policy .

Log Files

Like many websites, we utilize web server log files. These files include records such as internet protocol (IP) addresses (please refer to the "Device information" section below for additional details), browser types, internet service providers, referring pages, exit pages, platform types, and date/time stamps. The purpose of employing web server log files is to manage the site, provide comprehensive traffic information for site planning, and ensure compliance with our terms of service agreement. It is crucial to note that IP addresses in our web server log files are not linked to personal data.

Device Information

We collect information about the devices you use to interact with our services, encompassing the device's IP address (enabling us to deduce the country of connection), device type, operating system, application, and browser version. This data is gathered to prevent spam and abuse of our services. It is crucial to acknowledge that in specific jurisdictions, IP addresses may be deemed personal data. Therefore, they will be handled in accordance with the principles outlined in this privacy policy.

Analytics

During your usage of our Website, we may automatically collect analytics information, which includes general device details, device identifiers (such as the Google Advertising ID for Android devices or the Advertising Identifier (IDFA) for iOS devices), network information, and events related to website and application interactions. It is crucial to clarify that this analytics process only collects pseudonymous data, and no personally identifiable information from your profile is included.

We employ this information for the analysis and enhancement of our services and applications, as well as for the continuous development, testing, and improvement of our overall service. To achieve these objectives, we may utilize both internal analytics and third-party service providers. For further details regarding our use of third-party service providers, please refer to the Analytics Providers section below.

How do we use personal information?

We utilize personal data in diverse ways that are essential for providing the services you intend to use, aligned with certain legitimate interests, and as a requirement to comply with applicable laws, as elucidated further below.

Typically, we do not depend on your consent as the primary basis for processing your personal data if there exists another lawful ground. If, however, we do rely on your consent for specific processing activities, we will explicitly communicate this to you at the relevant time.

User Profile

A profile encompasses a collection of information specific to each individual user, outlining their viewing preferences. User settings, including chart settings, toolbars, buttons, etc., are retained solely to tailor the user's experience when utilizing the Website, applications, or user accounts. It is crucial to emphasize that private profile settings are not shared with any third parties.

It's important to note that when you create an account, other users or visitors may access your public profile and view any information you have chosen to make publicly available about yourself.

User Account and Profile Operations

We employ your contact details, including your username, email address, or phone number, for the following purposes:

To authenticate your user account, ensuring both its security and the security of our services, and to prevent spam, fraud, and abuse.
To recognize, confirm, and manage your user account.
To dispatch a activation and verifications emails to all new users, verifying their email address or those updating their account details.

User Account Deleting

You have the option to decline the use of our Website and can request the deletion of your account by asking us to delete your account in the Profile Settings. Account deletion will occur instantly.

Please be aware that upon your request for account deletion, we will erase the personal data you have provided us. However, certain data, such as published ideas/scripts and messages sent to other users, will be retained as an integral part of our system to uphold platform integrity.

For legitimate business processes and to comply with legal obligations, including tax laws, audits, and security measures, specific data must be retained for an extended period. This data encompasses, but is not limited to, transaction logs, financial records, addresses, and employment details. The retention duration for each data type will adhere to specific legal requirements, extending up to 10 years.

It's important to note that search engines and third parties may retain copies of your publicly available information even after your account has been deleted. Additionally, published ideas will persist on the site, and messages sent to other users cannot be deleted.

Marketing

We may dispatch marketing emails pertaining to our products or services, aligning with those you are subscribed to, and may include information about events and promotions that may be of interest to you. This is unless you have explicitly communicated your preference to not receive such communications. For any other promotional information sent via email, we will seek your consent, which was initially granted when you provided us with your personal data. Users have the option to opt out of receiving marketing communications at any time by clicking "unsubscribe" in one of the emails. For more information on your rights, please refer to the "User rights" section below.

Social Notifications

We have the capability to notify you via email about various activities, such as new users following you, likes on your ideas, and new ideas from users you follow. You retain the option to decline receiving such notifications at any time by adjusting your Profile settings.

Service-Related Announcements

In rare instances, there may be a necessity to send service-related announcements. For example, in the event of a prolonged service interruption or the release of a significant functionality upgrade, we may send all users an email message to communicate important information.

When do we share personal information?

We share your personal data with third parties in the following situations:

Analytics providers: We may use Google Analytics as a web analytics service on the Website, mobile apps and in conjunction with the widgets we provide. For more information on Google Analytics privacy practices, you can check here .

Public Information on our Site

Public Profile

When you create your profile on our Service, it is important to note that other users or visitors may access your public profile and view any information you have chosen to make available about yourself. During searches for strategies or ideas, they will have access to specific details such as your market information (published strategies and ideas, etc.), social information (followers, following lists, ideas you follow and comment on), contact information (About section, avatar, links to social media accounts, website, etc.), and community status (Moderator or Pro badges, statistical information like reputation points, views, likes, followers, registration date, as well as your last visit date or user creation date). However, your email address will not be visible unless you explicitly choose to make it so.

Public Content

Our Service provides registered user accounts with the ability to share their ideas with the broader internet through our publish features.

When utilizing the publish features, you provide us with an irrevocable, perpetual, and royalty-free license to publish and disclose the content, along with the identifiable username of the author.

Chats and Private Messages

When engaging in communication with other users through public and private chats, we store and process your messages along with any associated information. We conduct link checks to ensure there is no malicious software or content, and to detect spam and prohibited images/text.

It is essential to be aware that when using private messages to communicate, the recipients possess a copy of your correspondence. Even if you delete such messages from your account, recipients can retain, store, and/or reshare these messages. Therefore, it's crucial to exercise constant vigilance in this regard.

Security of personal data

We implement technical and organizational safeguards to ensure the protection of your personal data, and we require third parties with whom we collaborate to uphold similar standards.

To safeguard specific information you submit to us, we utilize Transport Layer Security (TLS) encryption technology. This technology ensures the protection of your information during transmission, preventing interception by unauthorized parties. When on a secure page, such as our order form, the "lock" icon in the browser window is displayed, indicating the establishment of a secure and encrypted connection with the Website. We are committed to maintaining a secure Service that aligns with industry standards. Additional security measures, including firewalls, authentication systems (e.g., passwords, personal identification numbers), and access control mechanisms, are employed to regulate unauthorized access to systems and data. If you choose to create an account, it is your responsibility to take reasonable measures to keep your access details confidential and not share them with others.

Offline, user information is limited to our offices, and only employees requiring access for job-related tasks are permitted to view it. The servers housing personal data are situated in a secure environment within a locked facility.

Continuous improvements are made to enhance the security, storage, and processing of the data we collect. Physical security measures are also implemented to counter unauthorized access to our systems. However, it is important to note that no electronic transmission or storage method is 100% secure, and therefore, we cannot guarantee absolute security.

Children and sensitive personal data

This Website is not intended for children under the age of 18. We do not knowingly contact or collect personal information from individuals below the age of 18, including sensitive personal data (as defined, for instance, by Art. 9 GDPR, encompassing information related to racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, genetic data, biometric data, data concerning health, or data revealing a person's sex life or sexual orientation). If you believe that we have unintentionally collected such information, please contact us promptly. This will enable us to either obtain special consent or delete the information as necessary.

Third Party Sites

Links to other sites

At our discretion, we may include links (web links) to other websites from our Website. These websites may be operated by third parties with distinct and independent privacy policies. Consequently, we bear no responsibility and assume no liability for the content, activities, or privacy policies of these linked sites. We recommend that you carefully read the privacy policy of each site you visit.

EEA and UK users' specific rights

Individuals subject to European and United Kingdom ("UK") data protection laws may have data subject rights in relation to the personal data we hold on them (described in detail below). This may, in and of itself, be subject to limitations and/or restrictions.

If you are located in the EEA or UK, please contact us to exercise your rights.

Accessing Data

If requested, we will verify whether we are processing your personal data, and if so, we will furnish you with a copy of that personal data along with any relevant details. In case you need additional copies, we may need to charge a reasonable fee. However, such circumstances can be discussed, and the fee depends on the specific situation.

Restricting the Processing of Personal Data

You have the right to request the restriction or 'blocking' of the processing of your personal data in specific circumstances, such as if you dispute the accuracy of the data or object to its processing. We will inform you before lifting any restriction on processing. If we have shared your personal data with others, we will strive to notify them of the restriction. Additionally, if feasible and lawful, we will inform you with whom we have shared or will share your personal data so that you can contact them directly if necessary.

Objections

You have the right to request us to cease processing your personal data at any time, and we will comply with your request. If we are relying on a legitimate interest as the basis for processing your personal data, unless we can demonstrate compelling legitimate grounds for such processing, we will respect your request.
You have the right to object to our processing of your data for the purposes of direct marketing at any time. This can be accomplished by clicking the "unsubscribe" button in our marketing emails.
You have the option to decline receiving service notifications via email, such as when a user you are subscribed to publishes a chart or idea. This adjustment can be made in the User Settings.

Withdrawal of Consent

If we depend on your consent to process your personal data, you retain the right to withdraw that consent at any time. The withdrawal of consent will not impact the lawfulness of the processing conducted before receiving notice of your decision to withdraw consent. It's important to note that, as a general practice, we do not primarily rely on your consent for processing your personal data if another lawful ground is available. If, however, we do rely on your consent, we will explicitly communicate this to you at the relevant time.

Viewing and Correcting Data

You have the right to have inaccurate personal data rectified or completed if it is incomplete. Each user can manage, view, and update their personal data in the Profile Settings to facilitate this process.

In the event that we have shared your personal data with others, we will strive to inform them of any corrections made. If prompted, and if it is possible and lawful to do so, we will also notify you with whom we have shared your personal data so that you can contact them directly if necessary.

Deleting Data

You have the right to refuse the use of our Services and may request us to delete or remove your personal data in certain circumstances. In cases where we have shared your data with others, we will strive to inform them of the modifications. If prompted, and where possible and lawful, we will also notify you with whom we have shared your personal data so that you can contact them directly if needed.

For more detailed information, please refer to the "User Account Deleting" section.

Data Retention

We will retain your personal data under the following conditions: (1) until you decide to delete your account (upon request), or (2) as required by law or necessary for legitimate business purposes, such as tax, legal, accounting, fraud prevention, abuse prevention, and/or other purposes. It's important to note that this data may be stored even after an account is deleted.

Upon the expiration of the applicable retention period, we will securely destroy your personal data in accordance with applicable laws and regulations. In certain circumstances, we may anonymize your personal data, rendering it no longer associated with you. In such cases, the data is no longer considered personal.

If you have given consent to receive marketing communications, we will keep your data until you choose to unsubscribe, which can be done through the 'unsubscribe' button at the end of our marketing emails. Additional methods to unsubscribe may be introduced in the future.

Data Portability

You have the right to obtain your personal data from us, including data you consented to provide or that was necessary for our contract with you. We will provide you with your personal data in a structured, commonly used, and machine-readable format, allowing you to reuse it elsewhere if you choose.

Lodge a Complaint with the Data Protectiojn Authority

If you have concerns regarding our privacy practices, including the handling or possession of your personal data, you have the option to report it to any competent data protection authority of a European Union member state authorized to address such concerns. You may find contact information for European Union Data Protection Authorities here . Additionally, you can report concerns to the Information Commissioner's Office (ICO), the UK supervisory authority for data protection issues.

If you wish to exercise any of your rights or make a report, please contact us. It's important to note that we may need to request further information to verify your identity before responding to any request.

International Data Transfers

Trifortuna is based in Germany. The information collected through our Services will be stored on servers located in the United States, the European Union, and other destinations, including locations outside the European Economic Area (EEA). This data is transmitted to our service providers and affiliated businesses for the purposes described above, facilitating your navigation and use of our Services. Additionally, the data may be transmitted to service providers and affiliates supporting our business operations, as outlined earlier.

It's important to note that the legal standards for the protection of personal data in the countries involved may not be equivalent to those in the EEA. If we transfer your personal data to countries outside your own, we will take the necessary measures to ensure that your information receives an adequate level of security protection where it is processed, and that your rights continue to be safeguarded.

For more detailed information on the safeguards we implement, please feel free to contact us.

California Users' Specific Rights

As an eligible California resident, the California Consumer Privacy Act ("CCPA") affords you specific rights concerning our collection and use of your personal information. You are entitled to the following rights under the CCPA.

You have the right to request that we disclose specific information about our collection and use of your personal information over the past 12 months. The list of categories of personal information collected and disclosed about consumers is provided in the section 'Personal data that we collect', and the list of categories of third parties to whom the personal information may be disclosed is outlined in the section 'When would we share personal information'. To exercise a data portability request, please contact us. Additionally, it is important to note that we do not sell your personal information.
You have the right to request the deletion of personal information that we have collected from you. For more details on how to delete your user account and the associated personal information, please refer to the "User Account Deleting" section.
You have the right not to be discriminated against regarding pricing and services as you exercise any of your rights under the CCPA. It's important to note that we do not offer consumers financial incentives, price differentials, or services in exchange for selling a consumer's personal information.

Contact Information

If you have any questions or suggestions regarding personal data processing, please contact us using this form or via post at:

Florian Köhler

Trifortuna e.U.

Karlsbader Str. 16

86690 Mertingen

Last updated Jan 16th, 2024