The purpose of this privacy policy is to formalize our commitment to respect the privacy of users of the subvertotradingclub.com website operated by Subverto Trading Club.

As part of the provision of our Site, we process your personal data in accordance with the General Data Protection Regulation 2016/679 of 27 April 2016 (“GPDR”) and under the conditions set out below.

Personal data refers to any information relating to an identified or identifiable natural person. We collect and process personal data in the context of providing our Services or communicating about them exclusively, in strict compliance with the RGPD. We only collect personal data that are adequate, relevant and limited to what is necessary for the purposes for which they are processed. Thus, you will never be asked to provide information on personal data considered “sensitive”, such as your racial or ethnic origins, political, philosophical or religious opinions.

If you do not agree with the terms of this Policy, please do not use the Site and the Services.

Date of last update: 19/04/19

We may collect and store your personal data, particularly when you :

  • Browse the Website
  • Leave a comment
  • Contact us for more information

We use your personal data to enable the implementation and management of the Site Services and to respond to your specific requests. We also use your personal data to operate and improve our Services, our Site and our approach. This information is only used by us and allows us to better tailor our Services to your expectations.

f you have decided to receive emails and messages from us when you subscribe to the Newsletter, you will then receive emails and alphanumeric messages about our products and promotions. We will then use the personal data you provided when you registered. You can unsubscribe from these mailings at any time. You can unsubscribe from these mailings at any time.

Browse on the Website

Connection data : Each time you connect to our Site, we collect personal data such as, but not limited to, your IP address and MAC address of your computer, the date and time of connection, and information about the browser you are using.

Navigation data : We also collect information to identify how you access the Site, which pages you visit and for how long. In this context, we may use Cookies as specified in paragraph 5 below. In any event, you have the right to withdraw your consent to receive such information letters at any time and without charge under the conditions provided for in paragraph 7 of the policy.

How do we protect your personal data?

You may give your prior consent to receive our newsletters regarding news, new products, services and promotions as part of the Services.

You may also directly consent to the receipt of our newsletters by providing your email address in the appropriate places on the Website.

In any event, you have the right to withdraw your consent to receive such information letters at any time and without charge under the conditions provided for in paragraph 7 of the Charter.

Contacts

In order to respond to any requests you may make to our Customer Service Department and to confirm information about you, we may use your full name, e-mail address and telephone number.

We have put in place technical and organisational security measures to ensure the security, integrity and confidentiality of all your personal data, in order to prevent it from being distorted, damaged or accessed by unauthorised third parties. We ensure an appropriate level of security, taking into account the state of knowledge, the costs of implementation and the nature, scope, context and purposes of the processing operation as well as the risks and their probability.

However, it is specified that since no security measure is infallible, we are not in a position to guarantee absolute security for your personal data.

Sharing your personal data with third parties

When you browse the Site, your personal data may be transmitted to external service providers. These third parties provide a service on our behalf and in our name to ensure the smooth operation of credit card payments and other Services. No transfer of personal data takes place outside the European Union.

In accordance with the GDPR, all transfers of personal data to a country outside the European Union and/or not offering a level of protection considered sufficient by the European Commission have been subject to cross-border flow agreements in accordance with the standard contractual clauses laid down by the European Commission. Except in the event that a third party asks you to accept a privacy policy and its own terms of use, the third party companies that have received your personal data have undertaken to process your personal data solely for the purpose of implementing our Services. We will never share your personal data with third parties for marketing and/or commercial purposes without your prior consent.

Sharing with the authorities

We may disclose your personal data to administrative or judicial authorities when their disclosure is necessary for the identification, arrest or prosecution of any individual likely to prejudice our rights, any other user or a third party. Finally, we may be legally required to disclose your personal data and cannot object in this case.

In any event, we will keep your personal data for no longer than is necessary for the purposes for which they are processed in accordance with the uses set out in this Policy and in compliance with laws and regulations.

If you leave a comment, the comment and its metadata are kept indefinitely. This is how we can automatically recognize and approve follow-up comments instead of putting them in a moderation queue.

What is a cookie?

A cookie is a text file that can be placed in a terminal when viewing an online service with a browser. In particular, a cookie file allows its issuer, during its validity period, to recognize the relevant terminal each time it accesses digital content containing cookies from the same issuer.

In any case, cookies placed on your navigation device with your consent are destroyed 13 months after they are placed on your device.

What are the cookies issued on our Site used for?

The cookies we issue allow us to:

  • To establish statistics and volumes of visits and use of the various elements composing our Site (sections and contents visited, routes), allowing us to improve the interest and ergonomics of the Site and, where applicable, of our products and services
  • Adapt the presentation of our Site to the display preferences of your device (language used, display resolution, operating system used, etc.) when you visit our Site, depending on the display or reading hardware and software that your device contains
  • If you leave a comment on our site, you can choose to save your name, email address and website in cookies. It is to make it easier for you that you do not have to fill in your details again when you leave another comment. These cookies will last for one year.

When you browse the Site, cookies from social networks may be generated, in particular by using the sharing buttons that collect personal data.

When you first visit the Site, a cookie banner will appear on your home page. A link provides more information on the purpose and operation of cookies and links to this Policy. Continued browsing on another page of the site or the selection of an element of the Site (in particular: image, text, link, etc.) indicates your acceptance to the deposit of the cookies referred to on your computer.

Integrated content from other websites

Articles on this site may include embedded content (e.g. videos, images, articles, etc.). The integrated content of other websites behaves in exactly the same way as if the visitor had visited the other website. These websites may collect data about you, use cookies, integrate additional third-party tracking and monitor your interaction with this integrated content, including tracking your interaction with the integrated content if you have an account and are connected to this site.

How can you control the cookies used?

You can configure your browser software at any time to store cookies in your device or, on the contrary, to reject them (either systematically or according to their origin). You can also configure your browser software so that you are offered the option of accepting or rejecting cookies from time to time, before a cookie can be stored on your device.

Warning: any setting may change your Internet browsing and your conditions of access to certain services requiring the use of cookies. We decline any responsibility regarding the consequences related to the degraded functioning of our services resulting from the impossibility of recording or consulting the cookies necessary for their functioning and that you have refused or deleted. This would be the case if you attempted to access our content or services that require you to be identified. This would also be the case if we (or our service providers) could not recognize, for technical compatibility purposes, the type of browser your device uses, its language and display settings, or the country from which your device appears to be connected to the Internet.

How to configure your browser software?

For the management of cookies and your choices, the configuration of each browser is different. It is described in the help menu of your browser, which will allow you to find out how to change your cookie preferences. Below you will find information about the main browsers.

Internet Explorer / Edge

  • In Internet Explorer, click on the Tools button, then on Internet Options.
  • On the General tab, under Navigation History, click on Settings.
  • Click on the Show Files button.

Firefox

  • Go to the Browser Tools tab and select the Options menu
  • In the window that appears, choose Privacy and click on Display cookies

Safari

  • Access the Settings via the browser menu (Safari, then Preferences)
  • Click on Privacy.

Google Chrome

  • Access the Settings via the button to the right of the URL bar or via the browser menu (Chrome, then Preferences).
  • Select Advanced Settings
  • Click on Content Settings and then on Cookies.

For more information on cookies, you can visit the CNIL website.

When visitors leave comments on the site, we collect the data indicated in the comment form, as well as the visitor’s IP address and the browser’s user agent chain to help detect spam.

An anonymous string created from your email address (also called hash) can be provided to the Gravatar service to see if you are using it. The Gravatar service privacy policy is available here: https://automattic.com/privacy/. After approving your comment, your profile photo is visible to the public in the context of your comment.

You are the only one who has provided us with the data in our possession, through the Website. You have rights to your personal data. In accordance with the regulations on the protection of personal data, in particular Articles 15 to 22 of the GDPR, and after proving your identity, you have the right to request access to, rectification or deletion of your personal data from us.

In addition, within the limits set by law, you also have the right to object to the processing, to limit it, to decide on the post-mortem fate of your data, to withdraw your consent at any time and to the right to the portability of the personal data provided.

You can contact our Services to exercise your rights at the following e-mail address: contact@subverto.comby attaching a copy of an identity document to your request.

In addition, you can unsubscribe from our newsletter at any time by clicking on the unsubscribe link at the bottom of each email. You can also unsubscribe by sending a message to the following address: contact@subverto.com.

We reserve the right to modify the Policy at any time. It is therefore recommended that you consult it regularly. n the event of any changes, we will post such changes on this page and in such places as we deem appropriate, depending on the purpose and significance of the changes made.

Your use of the Website after any changes mean that you accept those changes. If you do not agree to certain material changes to this Policy, you must stop using the Website.