1. Who we are
Gifford Trade Group FZCO (company number 62321), trading as Traders Coaching, is the organization responsible for the personal information described in this policy ("we", "us" or "our").
Address: Building A1, DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, Dubai, United Arab Emirates
Privacy contact: support@traderscoaching.com
2. Information we collect
Depending on how you interact with us, we may collect:
- identity and contact information, such as name, email address, country and contact details you provide;
- transaction information, such as products purchased, purchase date, price, currency, payment status, refunds and billing country;
- onboarding information you submit for product configuration, such as market preferences, platform information, account-size bands, trading experience, risk-setting preferences and time available to monitor a strategy;
- account and support information, such as login activity, content access, support messages, onboarding responses and membership status;
- device and usage information, such as IP address, browser, device type, pages viewed, referring page, approximate location derived from IP and cookie or advertising identifiers;
- marketing information, such as consent status, email engagement and advertising-attribution information; and
- information you voluntarily send us in forms, surveys, messages, calls or other communications.
Payment-card details are generally collected directly by our payment processor and are not stored by us in full.
3. Sensitive information and financial information
Please do not send us passwords, private keys, brokerage login credentials, full card numbers or other information that is not reasonably necessary for support.
Our onboarding questions are not designed to create a regulated investment profile. We do not ask for your full assets, liabilities or financial plan in order to provide individualized financial advice.
4. Why we use personal information
We may use personal information to:
- process orders, provide access and deliver purchased products or services;
- configure a requested product using the selections and parameters you submit;
- provide onboarding, technical support and customer service;
- administer memberships, renewals, cancellations and refunds;
- maintain transaction, tax, accounting, fraud-prevention and compliance records;
- secure, troubleshoot and improve our websites, products and customer experience;
- measure website and advertising performance, subject to consent where required;
- send service communications; and
- send marketing about our products where permitted by law, with an ability to opt out.
5. Legal bases for UK/EEA processing
Where UK GDPR or EU GDPR applies, our legal bases may include:
- contract: processing needed to take your order and provide what you purchased;
- legal obligation: processing required for accounting, tax, fraud prevention or lawful requests;
- legitimate interests: operating, securing and improving our business, handling customer service and measuring business performance, where those interests are not overridden by your rights; and
- consent: where required for non-essential cookies, certain advertising technologies or electronic marketing.
Where electronic marketing rules require consent or a valid customer 'soft opt-in', we will rely on the mechanism permitted by the applicable law rather than treating acceptance of this Privacy Policy as marketing consent.
6. Cookies, analytics and advertising
We use essential cookies or similar technologies needed for checkout, security and account access. We may also use analytics and advertising technologies, including technologies supplied by advertising platforms such as Meta, to understand performance and attribute advertising.
Where applicable law requires prior consent for non-essential cookies or similar technologies, those technologies should not be activated until valid consent is obtained. You should be able to reject non-essential cookies without losing access to basic site functions.
You can also use browser controls and, where available, our consent-management controls to change cookie choices.
7. Marketing communications
We may send marketing emails or similar communications when you have consented or when another lawful exception applies, such as a permitted existing-customer soft opt-in.
You can unsubscribe from marketing emails using the unsubscribe link or contact us at support@traderscoaching.com. Unsubscribing from marketing does not prevent necessary service messages about an active purchase or account.
8. Who we disclose information to
We may disclose personal information to service providers that help us operate the business, including:
- payment processors;
- website, funnel, portal and cloud-hosting providers;
- email, CRM, customer-support and messaging providers;
- analytics, attribution and advertising providers;
- professional advisers such as accountants, auditors and legal advisers; and
- fraud-prevention, security and compliance providers.
We may also disclose information where required by law, to enforce our legal rights, to protect users or systems, or as part of a genuine corporate transaction such as a reorganization, acquisition or sale.
We do not sell personal information for money. Depending on the technology used and the law that applies, disclosure of identifiers or online activity to advertising partners may be treated as 'sharing', 'sale' or targeted advertising even when no money changes hands. Where applicable, we will provide the legally required opt-out mechanism.
9. International transfers
We are established in the United Arab Emirates and use service providers in multiple countries. Your information may therefore be processed outside your country of residence.
Where a law requires safeguards for international transfers, we will use an approved transfer mechanism or other legally recognized safeguard, such as applicable standard contractual clauses, contractual protections or an adequacy mechanism.
10. Data retention
We keep personal information only for as long as reasonably necessary for the purposes described in this policy, including legal, accounting, tax, fraud-prevention and dispute-resolution needs.
As a general guide:
- transaction and accounting records may be retained for up to 7 years, or longer where law requires;
- customer account and support records may be retained while the account or relationship is active and for a reasonable period afterward;
- marketing suppression records may be retained as necessary to ensure we respect an opt-out; and
- cookie and analytics retention periods depend on the provider, configuration and consent choices.
We may retain a limited record after a deletion request where necessary to comply with law, establish or defend legal claims, prevent fraud, or maintain an unsubscribe/suppression preference.
11. Security
We use reasonable administrative, technical and organizational measures designed to protect personal information. No internet transmission or storage system can be guaranteed to be completely secure.
You are responsible for keeping your login credentials confidential and for notifying us if you believe your account has been compromised.
12. Your privacy rights
Depending on where you live and which privacy law applies, you may have rights to request access, correction, deletion, restriction, portability, objection, withdrawal of consent or information about our processing.
You may also have a right to complain to a privacy or data-protection authority. For example, UK residents can complain to the UK Information Commissioner's Office, and Australian residents may have rights under applicable Australian privacy law.
To make a privacy request, email support@traderscoaching.com. We may need to verify your identity before completing the request. We will respond within the timeframe required by applicable law.
13. United States state privacy rights
Residents of certain U.S. states may have additional privacy rights if the relevant state law applies to us, including rights to know/access, correct, delete or obtain a portable copy of personal information, and to opt out of certain targeted advertising, sale or sharing of personal information.
Where required, we will honor legally recognized opt-out preference signals, such as Global Privacy Control, for the browser or device sending the signal.
We will not discriminate against you for exercising a privacy right protected by applicable law.
14. Australian privacy
Where the Australian Privacy Act 1988 and Australian Privacy Principles apply to us, we will handle personal information consistently with those obligations, including reasonable security, access and correction rights and appropriate handling of overseas disclosures.
If you make an Australian privacy complaint, please contact us first at support@traderscoaching.com so we can investigate and respond.
15. Children
Our products and services are intended for adults aged 18 and over. We do not knowingly collect personal information from children for the purpose of selling these products.
16. Third-party websites and services
Our sites may link to brokers, prop firms, payment providers, social networks, software platforms and other third parties. Their privacy practices are governed by their own policies, not this one.
17. Changes to this Privacy Policy
We may update this Privacy Policy as our services or legal obligations change. We will update the 'Last updated' date and provide any additional notice required by law for material changes.
18. Contact
Gifford Trade Group FZCO (company number 62321), trading as Traders Coaching
Building A1, DSO-IFZA, IFZA Properties, Dubai Silicon Oasis, Dubai, United Arab Emirates
Email: support@traderscoaching.com