Last Updated: 28th June 2022
Who we are
What kinds of personal information do we hold about you?
How Do We Use Your personal information?
Where do we get your information from?
What are our legal grounds for using your information?
Who do we share your information with?
How Can You Access Your Data?
How long do we keep your personal information?
Do we make solely automated decisions about you or profile you?
What are your rights?
Right to complain to the supervisory authority
1. Who we are
T-Sniper Limited. (“us”, “we”, or “our”) and all our partners are owned and operated by T-Sniper Limited, registered in England under 10277162, VAT number 250 4795 30.
All websites are owned and data is controlled by T-Sniper Ltd, although each company is its owns legal entity.
We are not required to have a data protection officer, any enquiries about our use of your personal data should be sent to our legal team at email@example.com. We are a member of the Information Commissioner's Office (ICO) whose role is to uphold information rights in the public interest.
2. What kinds of personal information do we hold about you?
contact information such as email addresses and telephone numbers;
demographic information such as post code, preferences, and interests;
web browser type and version;
a list of URLs starting with a referring site, your activity on Our Site, and the site you exit to.
When we collect your information, we’ll let you know if any of it is optional. If it is, we’ll explain why it would be useful to us, and you can decide whether it’s something you’re happy for us to have.
2a. When you submit an enquiry via our website
When you submit an enquiry via our website, we ask you for your name, contact telephone number and email address. We use this information to respond to your query, including providing you with any requested information about our products and services. We may also email you several times after your enquiry in order to follow up on your interest and ensure that we have answered your it to your satisfaction. We will do this based on our legitimate interest in providing accurate information prior to a sale. We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 and GDPR.
2.b When you purchase a product from our website
When you purchase products from us online, we ask you for your name, address, contact telephone number, email address and credit card information. We also record your IP (Internet Protocol) address, which is the address of your computer on the Internet. We will use your information to verify your credit card details for your purchase, process your order and to send you your products. We will also send you a receipt via email and we may use your telephone number to contact you regarding your purchase. We require this information in order to process your payment, deliver your products or services and fulfil our contract with you. We record your IP address in order to show that the correct tax was applied to the sale, which we are required to do by law. Your information is stored on our website and on our cloud server. Your credit card details are passed to a third-party payment processor which is certified to the EU-US Privacy Shield (which requires effective safeguards for your information). We do not retain your credit card information. We keep your order information for an indefinite period, as the licenses we sell for our products do not expire.
2c. When you sign up to receive our newsletter
When you sign up to receive our newsletter, we ask for your name and your email address. We will ask for your consent to use your name and email address to email you our newsletter which contains information about our products and other information which we feel might be of interest to you. You can withdraw your consent at any time, and we will stop sending you the newsletter. Your name and email address are shared with a third-party mailing systems who use appropriate safeguards for your personal data which means it will be protected in line with the legal requirements of the European Union.
2d. When you download a white paper or ebook
When you request to download a sample document, such as a white paper or ebook, we ask for your name, company name (which is optional) and your email address. We use this information to email you a link to download the requested document. We may also email you after your download in order to follow up on your interest in our products and services. We will do this based on our legitimate interest in marketing to prospects for our products and services. Your name and email address are shared with a third-party mailing systems who use appropriate safeguards for your personal data which means it will be protected in line with the legal requirements of the European Union.
2e. When you submit a review about us
When you submit a review about us, we record your name, your email address and your IP (Internet Protocol) address, which is the address of your computer on the Internet. We use this information to provide verified independent views about our products and services to potential customers. Your name and the content of your review (but not your email address or IP address) may be publicly displayed on our website. We will do this based on our legitimate interest in marketing our products and services. Your details are shared with a third-party reviews system who use appropriate safeguards for your personal data which means it will be protected in line with the legal requirements of the European Union.is based within the European Economic Area (EEA).
2f. When you take part in our feedback survey
When you take part in our feedback survey, we record your name, your email address, your organisation name, your job role and your answers to questions we ask about your opinion of, and use of, our products and services. We use this information to develop and improve our products and services and our customer relationships. Your job role, organisation and some or all of your comments may be publicly displayed on our website as a testimonial. We will do this based on our legitimate interest in marketing our products and services. Your details are shared with a third-party reviews system who use appropriate safeguards for your personal data which means it will be protected in line with the legal requirements of the European Union.is based within the European Economic Area (EEA).
3. How Do We Use Your personal information?
All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the Data Protection Act 1998 and GDPR at all times. Our use of your personal data will always have a lawful basis, either because it is necessary for Our performance of purchasing a product or service with us, or because you have ‘consented’ to Our use of your personal data (e.g. by subscribing to newsletter or ticking a box consenting to receive information), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
Providing and managing your account profile in the Trading & Investing Academy;
Providing and managing your access to Our Sites;
Personalising and tailoring your experience on Our Sites;
Supplying Our services to you (please note that We require your personal data in order to provide services to you;
Personalising and tailoring Our services for you;
Replying to emails from you;
Supplying you with emails that you have opted into (you may unsubscribe or opt-out at any time by by clicking on the opt-out at the bottom of your emails;
Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience.
With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email AND/OR telephone AND/OR text message AND/OR [post] with information, news and offers on Our services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the [Data Protection Act 1998 OR GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003.
4. Where do we get your information from?
Most of the information we receive comes directly from you. We may also get personal information about you from other sources:
Directly from you: You may have opted into our communications by ticking a tickbox via newsletter, ebooks, training material or by purchasing one of our services or products.
Partners: Where you have purchased some training or educational materials from one our partners.
5. What are our legal grounds for using your information?
Data Protection gives organisations a number of different conditions to allow us to process your information lawfully. We’ll only use your personal information when one of these conditions has been satisfied. Below you can see how we use your information and the legal grounds for processing this:
Legal GroundsUse of your informationConsent
Your personal information may be processed when we receive your consent.
The consent you provide must be freely given, informed, specific, unambiguous and be given with a positive affirmative action.
Your consent can be withdrawn at any time.
Necessary for the performance of a product or service.
The personal information you provide or that of a joint party to the contract may be processed when it is necessary to deliver a service you have purchased. E.g. where we process your information to set up you membership account for the Trading & Investing Academy.
Setting up and administering your product or service.
Product /service surveys
Product / service emails
Analytics data reporting
User management tracking on the platform
We may be provided with information by organisations that introduce you to us when you have shown an interest in one of our products e.g. T-Sniper software.
Necessary for legitimate interests
We also use your information when we have a “legitimate interest” and that interest isn’t outweighed by your privacy rights. Each activity is assessed and your rights and freedoms are taken into account to ensure that we’re not being intrusive or doing anything beyond your reasonable expectation. We’ll assess the information we need, so we only use the minimum.
If you want further information about processing under legitimate interests you can contact us using the details below. You also have the right to object to any processing done under legitimate interests. We’ll re-assess the balance between our interests and yours, considering your particular circumstances. If we have a compelling reason we may still continue to use your information.
We use legitimate interests for the following:
Use of your informationLegitimate interest(s)Assessing and developing our products, systems, prices and brand
Our products are developed with a particular set of customer needs in mind. In order to make sure your policy is still suitable for you and is working as we intended, we combine your information with other customers’ to analyse and segment it.
We also combine your information with other customers’ to assess how much money we need to have available at any time.
We need to be able to identify groups of customers who might be interested in any new products or services we’re considering.
We need to develop those products and services, and make sure our product charges are fair.
We need to make sure we’re treating you fairly and check your policy remains suitable for you.
We need to make sure we’re looking after your money.
Researching our customers’ opinions and new ways to meet our customers’ needs
We may conduct research before we launch new products or before we make changes or improvements to existing products to make sure it’s the right thing to do. We might also conduct research to ask customers what they think about our products and services.
We need to make sure our products are suitable for the intended audience and to identify gaps in the market.
We need to see how many categories of customers we have and to tailor our products and services accordingly.
We need to make sure our communications use the right language and that our products are being sold to the intended set of customers.
We need to make sure our research is efficient and connects with the right types of people, so we can be confident of any decisions we make based on the results.
Sending you marketing communications about products and services
To send you information relating to your products and other products you may be interested in and highlight the benefits of our services. We won’t do this if you have told us not to.
We may source contact information in order to market new products to you or promote brand awareness and the benefits of your existing products. We may analyse your personal information to create a profile so that we can contact you with information relevant to you.
We need to ensure our communications are in line with our values as a educator in finance.
We also need to grow and sustain our business and develop our brand and effectively communicate with our members.
Monitoring the use of our websites
On our websites we use a variety of technologies that collect information about how visitors use our website.
We need to make sure that our websites are secure and work well.
6. Who do we share your information with?
We may share your data with our partners: Alpha4All Limited, Alpha4All Academy S.L., Assistenza Brokers srl, T-Sniper Limited. We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law. We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
7. How Can You Access Your Data?
You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, We will provide any and all information in response to your request. Please, complete the subject data request. You can also manage our email preferences and choose what type of information you would like to receive by clicking ‘managing preferences’ at the bottom of every email.
8. Overseas Transfers
We may sometimes use third party data processors that are located outside of the European Economic Area (“the EEA”) (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein). Where We transfer any personal data outside the EEA, We will take all reasonable steps to ensure that your data is treated as safely and securely as it would be within the UK and under the Data Protection Act 1998 and GDPR. These services will be carried out by experienced and reputable organisations on terms which safeguard the security of your information and comply with the European data protection requirements. We always ensure all personal information is provided with adequate protection and all transfers of personal information outside the EEA are done lawfully.
Once we receive your information, we use strict procedures and security features to protect your information from unauthorised access. We only work with third party suppliers who are GDPR compliant and who have strict security procedures in place, for example:
Industry standard data protection for ISO 27001 and SOC 2 Type 2;
Certified its compliance with the EU-U.S. Privacy Shield Framework;
Encrypt and anonymize users for extra protection.
We have strict data processing agreements in place with all providers who are subject to audits to ensure compliance.
10. How long do we keep your personal information?
We’ll keep your personal information for as long as it’s considered necessary, for the purpose for which it was collected, and to comply with our legal and regulatory requirements. This will involve keeping your information for a reasonable period of time after your plan or your relationship with us has ended.
11. Do we make solely automated decisions about you or profile you?
Automated decisions are where a computer makes a decision about you without a person being involved. We also profile our customers - which means we make assumptions about you to help us treat you fairly.
If you purchase a product or service or download our free material we will make an automated decision. Following the purchase we may contact you with other related services to compliment your experience.
Profiling is an automated processing of personal data to evaluate certain things about an individual. Profiling can be part of an automated decision-making process. This determines whether we have other products or service you may benefit from in the future. In the future we’d like to keep a note of the category you fall into, against your records, so we can tailor our communications to suit you.
12. What are your rights?
Your rights are outlined below. The easiest way to exercise any of your rights would be to contact our Data Protection Officer at the contact details provided. We’ll provide a response within 30 days, if not sooner. There’s normally no charge for exercising any of your rights.
Accessing your personal information
You have the right to find out what personal information we hold about you, in many circumstances.
Correcting or adding to your personal information
If any of your details are incorrect, inaccurate or incomplete you can ask us to correct them or to add information.
In some circumstances you can ask us to send an electronic copy of the personal information you have provided to us, either to you or to another organisation.
Objecting to the use of your personal information for legitimate interests
You also have the right to object to any processing done under legitimate interests. We’ll re-assess the balance between our interests and yours, considering your particular circumstances. If we have a compelling reason we may still continue to use your information.
Objecting to direct marketing
You have a specific right to object to our use of your information for direct marketing purposes, which we will always act upon.
Restricting the use of your personal information
If you are uncertain about the accuracy or our use of your information, you can ask us to stop using your information until your query is resolved. We will let you the outcome before we take any further action in relation to this information.
Right to Erasure
You can ask us to delete your personal information in some circumstances, such as if your policy has ended and we do not need to keep your information for legal or regulatory reasons. If we are using consent to process your information and you withdraw it, you can ask us to erase your information.
13. Right to complain to the supervisory authority
If you’re unhappy with how we’re using your information, you have the right to complain to the Information Commissioner’s Office. We’d encourage you to contact us first, so we can deal with your concerns.
14. Contacting Us