Privacy Policy
Data controller: Traders Temple Ltd, company number 10835955 Registered office: 12 Gateway Mews, Bounds Green, London, England, N11 2UT Privacy contact: admin@traderstemple.com
1. Scope
Traders Temple Ltd (“Traders Temple”, “we”, “us”, “our”) is the data controller for personal data processed through the Traders Temple public website, Foundation School, account services, Trader Match, contact and support routes, complaint handling, and voluntary newsletter preferences.
This policy explains what we process, why we process it, how long we keep it, the service providers involved, and the rights available to you. Traders Temple provides education and informational comparison tools; it does not provide personalised investment advice.
2. Day‑1 processing
Accounts and Foundation School
We process your email address, hashed password, account identifier, email-verification state, enrolment state, lesson progress, required-practice completion flags, completion timestamps, request/idempotency records and account-security records. Private written practice remains on your device and is not sent to Traders Temple.
Purposes and lawful bases: processing needed to create and administer the requested account, provide Foundation School and maintain the learner’s progress is necessary for performance of the service contract. Account security, abuse prevention, service integrity and operational reliability are processed under Traders Temple’s legitimate interests in protecting users and operating a safe, dependable service. A legal obligation is relied on only where a specific applicable law requires the processing. Traders Temple maintains appropriate legitimate-interests assessment and accountability evidence for processing based on legitimate interests.
Contact, Support and Complaints
When you contact us, we process the information you submit, relevant contact details, routing/classification information, acknowledgements, correspondence and outcome records. Routine enquiries may be classified or drafted with AI assistance under bounded controls. Legal, privacy, material complaint, security and consequential commercial matters are escalated for human judgement.
Purposes and lawful bases: information necessary to take requested pre-contract steps or to administer an existing customer service is processed for those steps or performance of the applicable service contract. General enquiries that are not contractually necessary are processed under Traders Temple’s legitimate interests in responding to enquiries and operating effective customer support. Complaint administration, service integrity and the establishment, exercise or defence of legal rights are processed under legitimate interests; a legal obligation is relied on only where a specific applicable law requires the processing. Traders Temple maintains appropriate legitimate-interests assessment and accountability evidence for processing based on legitimate interests.
Trader Match
Trader Match processes the questionnaire answers needed to compare your jurisdiction, trading approach and stated requirements against independently verified programme rules. The Day‑1 free version creates a short-lived anonymous capability-protected profile. It does not require an email address, does not save a named customer profile and does not activate marketing. Programme-link visits may be recorded as bounded operational events with the programme and dataset version so the service can be monitored and evidence kept current.
Commercial or affiliate status does not influence firm admission, programme qualification, compatibility, scoring or ranking.
Purposes and lawful bases: questionnaire and profile processing necessary to provide the comparison you request is processed to take steps at your request and perform the free Trader Match service. Security, abuse prevention, service integrity, bounded operational monitoring and reliability are processed under Traders Temple’s legitimate interests in protecting the service and ensuring it operates as intended. Traders Temple maintains appropriate legitimate-interests assessment and accountability evidence for that processing.
Voluntary newsletter preferences
If you voluntarily opt in, we process your email address, consent version, consent timestamp, source and subscription status. An unsubscribe creates a suppression record so that the address is not re-added or sent future newsletter messages. The Day‑1 infrastructure records preferences only; no newsletter campaign is active at launch.
Purposes and lawful bases: the subscription and any future authorised newsletter messages are processed on the basis of consent. Consent evidence is retained for as long as reasonably necessary to demonstrate compliance. After withdrawal or objection, only the minimum suppression information reasonably necessary to honour that choice and prevent an unauthorised re-subscription or send is retained for that purpose under Traders Temple’s legitimate interests in respecting preferences and demonstrating compliant operations, and under a legal obligation only where a specific applicable law requires it. You may withdraw consent at any time.
Technical, security and aggregate operational measurement
Hosting and application systems necessarily process request information such as IP address, timestamps, user agent, response/error information and bounded diagnostic records. Traders Temple also keeps daily aggregate counts for critical Day‑1 routes and success/failure events. These aggregate counters contain no profile, email, cookie identifier or cross-site behavioural history and are used only to determine whether essential journeys work.
Purposes and lawful bases: security, abuse prevention, fault diagnosis and reliable soft-launch operation (legitimate interests).
3. Cookies and browser storage
Day 1 uses only storage required to provide or secure the requested services: WordPress authentication/session cookies; short-lived session storage for the in-progress Trader Match questionnaire; and Foundation browser storage for owner-scoped cache, bounded retry/outbox handling, temporary restoration and device-local written practice.
The daily aggregate operational counters do not set an analytics cookie or build a visitor profile. Traders Temple does not operate advertising cookies, cross-site tracking or non-essential behavioural analytics on Day 1. Any future non-essential analytics or marketing technology will be assessed, documented and, where required, held behind prior opt-in consent before activation.
4. Recipients, processors and storage
Day‑1 services use:
- Hostinger: website, WordPress, database, account/progress storage, forms, server infrastructure, backups and the active Day‑1 transactional email service delivered through Hostinger SMTP.
- Supabase (EU region): Trader Match capability-protected profiles, questionnaire state, matching results and bounded operational events.
Brevo (Sendinblue) is not commissioned for Day 1 and receives no Day‑1 personal data. Any future Brevo or newsletter-delivery commissioning will require processor, privacy and transfer reconciliation before personal data is transferred. Recording a newsletter preference does not activate a marketing campaign or transfer subscriber data to Brevo.
Traders Temple does not sell personal data or share it for cross-context behavioural advertising. Opening an official third-party programme link sends you to that firm’s website; the destination then processes your visit under its own privacy terms.
Where processing involves an international transfer, Traders Temple will use an applicable adequacy decision, the EU Standard Contractual Clauses, the UK International Data Transfer Addendum or another lawful safeguard, together with relevant contractual and security controls.
5. Retention
- Active account and Foundation records: retained while the account is active and required to provide the service.
- Inactive accounts: scheduled for deletion or irreversible anonymisation after 24 consecutive months without account activity, subject to legal holds and a verified operational deletion process.
- Trader Match anonymous profiles/capabilities: 24 hours.
- Application diagnostic and server logs: normally 30 days, unless a shorter provider period applies or a bounded security/legal incident requires limited extended retention.
- Daily aggregate operational counters: 35 days.
- Contact and support: retained only as long as needed to resolve and evidence the enquiry, normally no more than 24 months after closure unless a shorter period applies.
- Complaints, legal, privacy and security matters: retained for the period needed to meet applicable limitation, regulatory, evidential and security obligations.
- Newsletter consent records: retained while subscribed and, after withdrawal, for as long as reasonably necessary to demonstrate compliance. No arbitrary fixed post-withdrawal period is applied without supporting evidence.
- Suppression records: only the minimum information reasonably necessary to honour an unsubscribe or objection and prevent an unauthorised re-subscription or send is retained for as long as reasonably necessary for that purpose, unless a lawful deletion request can be fulfilled without undermining it.
- Backups: expire under the provider-managed daily/weekly restoration cycle. A restoration is subject to reconciliation controls so previously completed erasure and suppression actions are re-applied.
6. Security and automated assistance
We use access controls, capability tokens, encryption in transit, data minimisation, bounded logging, fail-closed matching controls and environment separation. No internet service can be guaranteed completely secure.
AI may assist with routine classification, monitoring and drafting. It is not authorised to make personalised trading decisions or final consequential legal, privacy, complaint, security or commercial judgements. Those matters are escalated for human decision.
7. Your rights
Depending on applicable law, you may have rights to access, correct, erase, restrict or object to processing, receive portable data, and withdraw consent. Withdrawing consent does not affect processing already lawfully performed. You may also complain to the UK Information Commissioner’s Office or another competent supervisory authority.
Contact admin@traderstemple.com to exercise a privacy right. We may request proportionate identity verification before disclosing or changing account data.
8. Children
Day‑1 account services are intended for adults aged 18 or over. Traders Temple does not knowingly offer the account service to children.
9. Changes
We will publish the effective version and date when this candidate is approved. Material changes will receive an appropriate notice. A new use that requires consent will not begin until the required consent mechanism is in place.