1. DEFINITION OF TERMS

In this Privacy Policy, the following terms are used with the following meanings:
1.1. Site means any Internet resource owned or operated by the Company, including but not limited to https://offer.thomaskralow.com / and https://thomaskralowacademy.com /, including its subdomains, localized versions,and digital environments directly controlled by the Company through which Users may access the Programs or related services.

1.2. “Company”, “we”, “us” refers to Trading Education OÜ, a private limited company incorporated in Estonia, acting as the provider of educational content, materials, and related digital services offered via the Site.

1.3. “Participant”, “User”, or “you” means a natural person of legal age and full legal capacity who accesses or uses the Programs for personal educational purposes, in accordance with the Terms and Conditions.

1.4. “Personal Data” means any information relating to an identified or identifiable natural person, as defined under applicable data protection laws, including but not limited to:

information provided by the User during registration or in the course of using our programs and services;
automatically collected technical data such as IP address, cookie identifiers, browser type, device specifications, timestamps, and navigation paths;
any other information voluntarily submitted by the User or generated in connection with the use of our programs and services

1.5. “Services” or “Programs” refers to the non-formal digital education initiative operated by the Company, comprising access to learning modules, support tools, resources, and thematic content as described in detail on the Site.

1.6. “Services” means access to educational tools, materials, and related digital content developed and operated by the Company through its official websites. This includes, but is not limited to, the following domains and their respective subdomains and language variants:

https://thomaskralowacademy.com, https://offer.thomaskralow.com, https://clubthomaskralow.com, https://www.clubkralow.com,
https://www.thomaskralowclub.com, https://sale.thomaskralow.com, https://kralowwolf.com ,https://gamechangercommunity.com

1.7. “Processing” means any operation or set of operations performed on Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure, dissemination, alignment, restriction, erasure, or destruction.

1.8. “Confidentiality” means the obligation not to disclose Personal Data to unauthorized third parties without a legal basis or the explicit consent of the data subject.

1.9. Confidentiality of personal data is the requirement, mandatory for compliance by the person who has gained access to personal data, not to allow their distribution without the consent of the subject of personal data or the presence of another legal basis.

1.10. “Controller” means the legal entity (in this case, the Company) that determines the purposes and means of processing Personal Data.

1.11. “Consent” means any freely given, specific, informed, and unambiguous indication of the User’s wishes by which they, through a statement or clear affirmative action, signify agreement to the processing of their Personal Data.

Unless otherwise required by context:

words denoting the singular include the plural and vice versa;
words denoting gender include all genders;
references to terms such as “including”, “in particular”, or similar shall be construed as illustrative, not limiting;
section headings are for convenience only and do not affect interpretation.

2. GENERAL PROVISIONS

2.1. This Privacy Policy applies to data collected on the Site and any other resources used or owned by Site and Company. The Site includes any web pages, interactive features, applications, widgets, blogs, social media plug-ins, and online and offline offers that link to this Privacy Policy.

2.2. The Company may collect and process your Personal Data for the purpose of delivering, maintaining, improving, and supporting the Programs, as well as for ensuring legal compliance, user support, analytics, and communications consistent with this Policy.

2.3. The Company is committed to protecting the privacy and integrity of all Personal Data processed through its Sites and Services. We uphold high standards of data confidentiality and transparency and aim to create a secure and respectful environment for all Users.

2.4. This Policy explains how we collect, use, disclose, and protect your Personal Data when you access the Site or participate in the Programs. This Policy does not apply to the practices of third-party websites, platforms, or entities not owned or controlled by the Company, even if linked to from our Site.

2.5. As the data controller, Trading Education OÜ determines the purposes and means of processing your Personal Data, in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”).

2.6. By registering on any of the Sites, using the Services, or otherwise affirmatively consenting through available mechanisms (e.g., checkbox, submission form, platform registration), you provide your informed and voluntary consent to the collection, use, storage, transfer (including to authorized service providers), and other forms of Processing of your Personal Data as described in this Policy.

2.7. To receive more detailed information related to the protection of personal data, if you have any questions or doubts about our processing of your personal data or want to submit a request, you can contact us by sending an e-mail with detailed information to the e-mail address: support@thomaskralow.com.

3. DATA WE COLLECT ABOUT YOU

3.1. Depending on your interaction with the Site and participation in the Programs, we may collect, process, store, and use different types of Personal Data, including the following categories:
3.1.1. Data you voluntarily provide to us, including when you register an account, complete forms, contact support, subscribe to updates, or otherwise communicate with the Company. This may include:

your full name;
email address;
telephone number;
country or city of residence;
IP address;
account credentials (if applicable);
any other information you choose to provide through forms, support interactions, or correspondence.

By submitting such information, you consent to its processing in accordance with this Privacy Policy. You may also be asked to provide your consent to receive marketing communications, which you may withdraw at any time by using the opt-out mechanism provided in our messages.
3.1.2. Technical Data, collected automatically through your use of the Sites or Programs, including:

device and browser information (e.g., type, version, plugins);
operating system and interface settings;
time zone, language preferences, and screen resolution;
IP address and general location data (city-level);
interaction logs such as clicks, scrolls, hover actions, and navigation paths;
diagnostics and performance data (e.g., loading errors or session duration);
usage of cookies, pixel tags, or similar technologies.

3.1.3. Usage Data, which includes information about how you interact with programs and services, such as which materials you access, how frequently you log in, and how long you engage with specific features.
3.1.4. Marketing and Preference Data, such as your consent status, communication preferences, and engagement with newsletters or promotional content (if any).
3.1.5. Communication Data, such as records of your correspondence with our support team, submitted forms, chat messages, survey responses, and related metadata.
3.1.6. Anonymous or Pseudonymized Data, which may be generated by removing identifiers from collected Personal Data. We may use such data to analyze trends, improve user experience, and enhance the functionality of our programs and services. Anonymous data may be shared with third parties at our discretion, provided it cannot be used to identify an individual.
3.2. We may also process aggregated data, such as statistical summaries or generalized demographic indicators. While such data may be derived from Personal Data, it is not considered Personal Data under applicable law unless it is combined in a manner that directly or indirectly identifies an individual. If we do link aggregated data to your identity, it will be treated as Personal Data and processed accordingly.
3.3. We do not collect or process any special categories of Personal Data as defined by Article 9 of the GDPR. This includes, but is not limited to, information relating to your race, ethnicity, religion, political opinions, trade union membership, sexual orientation, health status, or biometric identifiers.

5. PURPOSES OF THE PERSONAL DATA USAGE

5.1. We process your Personal Data only when there is a valid legal basis under applicable data protection laws, including:

to perform our contractual obligations under the Terms of Use;
to comply with legal and regulatory obligations;
to pursue our legitimate interests (provided that such interests are not overridden by your fundamental rights and freedoms);
where you have provided your explicit consent (e.g., for marketing communications).

5.2. Specifically, we use and may disclose your Personal Data for the following purposes:

to register you as a User and provide access to our programs and services;
to process payments and manage transactional records;
to deliver support, resolve inquiries, and maintain communication with you;
to notify you of updates to the Site, programs and services, Terms of Use, or this Policy;
to collect insights on how Users interact with our programs and services,
to analyze market behavior and participant preferences, in support of business development and communication strategies;
to administer, monitor, troubleshoot, and improve the technical performance and security of the Site and Program;
to maintain secure backups and data recovery systems;

to share data with trusted service providers or contractors, bound by confidentiality and data protection agreements;
to ensure compliance with the Terms of Use and enforce our rights;
to protect the safety and rights of Participants, third parties, and the Company;
to comply with legal requests, court orders, and government requirements;
to obtain legal, accounting, and professional advice;
to exercise or defend legal claims;
to respond to legitimate law enforcement or national security requests;
for any additional purpose where you have expressly consented.

5.3. With your consent, we may use your identity, contact details, technical and usage data to inform you about services, offers, or updates that may be relevant to your interests (“marketing communications”). You may receive such communications if:

you have previously requested information or subscribed to our programs and services; and
you have not opted out of receiving such messages.

5.4. You may withdraw your consent to receive marketing communications at any time by:

clicking the “unsubscribe” link in our emails;
adjusting your preferences in your account settings (if available); or
contacting us at: support@thomaskralow.com.
.

6. PERSONAL DATA DISCLOSURE

6.1. We treat all Personal Data as confidential and do not disclose it to third parties except as permitted under this Privacy Policy, required by law, or authorized by your explicit consent. We do not sell, rent, or trade your Personal Data to any other party. Disclosure may occur solely for the purposes of providing and improving our programs and services, complying with legal obligations, protecting our legitimate interests, or where necessary to perform a contract with you.

6.2. We may disclose your Personal Data to trusted service providers, agents, subcontractors, or affiliated companies who assist us in delivering our programs and services. These third parties may include technical infrastructure providers, customer support platforms, payment processors, marketing and analytics providers, and legal or professional advisors. All such parties are bound by strict contractual obligations to process your data in accordance with applicable data protection laws and solely for the purposes specified by the Company.

6.3. We may also disclose your Personal Data if required by law, judicial process, or governmental authority, or if necessary to enforce our Terms of Use, investigate fraud or security incidents, protect our rights or those of other Users, or ensure compliance with legal and regulatory requirements. In the event of a corporate restructuring, including merger, acquisition, asset sale, or insolvency, your data may be transferred to a successor entity, subject to continued protection under this Policy and applicable law.

6.4. The Site may contain links to third-party websites or services. Please be aware that such sites operate independently and have their own privacy practices. We are not responsible for the content, terms, or data handling of these external services and encourage you to review their policies before interacting with them or submitting any Personal Data. 6.5 Our Sites may contain links to the websites or services of our partner networks, advertisers, transaction processors, etc. If you link to any of these websites or services, please note that these websites and any services that may be available through them have their own privacy policies and we are not responsible for such policies or for any information, including personal data, that may be collected through these websites or services, such as contact and location data. Please read these policies before submitting any information or personal data to these websites or using these services.

7. SAFETY

7.1. We are committed to maintaining the security and confidentiality of your Personal Data and have implemented appropriate technical and organizational measures to protect it against unauthorized access, alteration, disclosure, destruction, or other forms of unlawful processing in accordance with applicable data protection laws. Access to your Personal Data is strictly limited to authorized employees, contractors, or service providers who are bound by confidentiality and data protection obligations and who require such access in order to perform their designated functions.

7.2. All Personal Data exchanged between you and the Site is transmitted via secure SSL (Secure Socket Layer) technology and is encrypted to prevent interception. In the case of online payments, transaction data is encrypted during transmission and processing. If you are provided with (or choose) a password to access certain sections of our programs and services, you are solely responsible for maintaining the confidentiality of such credentials and must not share them with third parties.

7.3. While we implement industry-standard safeguards to protect your information, you acknowledge that no method of transmission over the Internet or method of digital storage can be completely secure. We therefore cannot guarantee absolute security of your data, although we make every reasonable effort to prevent security breaches.

7.4. Depending on the specific risks associated with the processing of your Personal Data, we may implement additional protective measures, including but not limited to: staff training and internal privacy protocols, physical access controls, encryption and pseudonymization techniques, data availability and recovery mechanisms, and regular system audits.

7.5. We also maintain procedures for detecting and responding to potential Personal Data breaches. In the event of a confirmed breach that may pose a risk to your rights and freedoms, we will promptly notify you and the relevant supervisory authority in accordance with applicable law.