Privacy Policy

This Privacy Policy describes how Trading Interview B.V. ("we", "us", or "our") collects, uses, shares, and protects your personal information when you visit or make a purchase from www.tradinginterview.com (the "Site") or use our e-learning services. We automatically pseudonymise dormant accounts and orders after 24 months of inactivity and retain pseudonymised order records for up to 10 years to comply with Dutch bookkeeping law.

1. Personal Information We Collect

Information You Provide Directly

When you register, make a purchase, or use our services, we collect:

• Account Information: First name, last name, email address, username, (hashed) password
• Order Information: Billing address, country of residence (required by Dutch tax law)
• Course Data: Course enrollment, module completion, quiz scores
• Payment Information: Processed securely through our payment provider Stripe

All identifying fields are removed after 24 months of inactivity; see § 6 ‘Data Retention’.

Information Collected Automatically

When you visit our Site, we automatically collect:

• Device Information: IP address, browser type, operating system, device identifiers
• Usage Information: Pages viewed, time spent, referring websites, login times
• Technical Data: Time zone, language preferences, error logs, access logs
• Aggregated Analytics: Country / region / city, browser family, OS family, referrer and page-path trends. Collected via Plausible Analytics; no cookies or persistent identifiers are set.

Plausible Analytics is cookieless: It generates anonymous usage statistics without writing any cookies or storing personal identifiers.

2. Legal Basis for Processing

Purpose	Legal Basis
Account creation and service delivery	Contract performance (Article 6(1)(b) GDPR)
Processing payments and invoicing	Contract performance & Legal obligation (Dutch tax law)
Customer support	Contract performance & Legitimate interests
Platform security and fraud prevention	Legitimate interests (Article 6(1)(f) GDPR)
Service improvements and analytics	Legitimate interests
Marketing communications (if subscribed)	Consent (Article 6(1)(a) GDPR)

3. How We Use Your Information

We use your personal information to:

• Provide access to our e-learning platform
• Process orders and payments
• Track your learning progress
• Provide customer support
• Comply with legal obligations (tax records, invoicing)
• Prevent fraud and ensure platform security
• Improve our services through aggregated or pseudonymised analytics.
• Send service-related communications
• Send marketing communications (only with your consent)

4. International Data Transfers

When we transfer your personal data outside the European Economic Area (EEA), we ensure adequate protection through:

• Data Processing Agreement (DPA): We have a data processing agreement with onRocket.com LLC
• Technical Measures: AES-256 encryption at rest, TLS 1.3 encryption in transit
• Organizational Measures: Strict access controls, regular security audits

5. Data Sharing

We share your personal data only with:

Service Providers (Data Processors)

• onRocket.com LLC: Hosting services
• Stripe: Payment processing - Privacy Policy
• PayPal: Payment processing - Privacy Policy
• Moneybird B.V.: Cloud bookkeeping & invoicing (EU-based)
• Plausible Insights: Privacy-friendly website analytics, cloud-hosted in Germany – Data Policy

Other Disclosures

We may disclose your information when required by law, court order, or to protect our legal rights.

We do not sell your personal data or share it for third-party marketing purposes.

6. Data Retention

• Web-shop accounts & course progress – Pseudonymised automatically 24 months after the last activity/login.
• Order-level personal data in WooCommerce – Pseudonymised at the same 24-month mark; numeric order ID and financial totals are kept to link with the invoice.
• Invoices & bookkeeping data (Moneybird) – Retained 10 years (Articles 52–57 Dutch State Taxes Act).
• Quiz scores (leaderboards) – Deleted at 24 months; only anonymised top-50 scores remain.
• System logs & IP addresses – 90 days.
• Encrypted off-site backups – 30-day rolling retention.
• Audit logs of the anonymisation tool – Stored indefinitely for accountability; reviewed every 3 years.
• Plausible analytics data – Aggregated and anonymised; retained for up to 60 months in line with our subscription tier.

7. Your Rights (GDPR)

As an EU resident, you have the right to:

• Access: Request a copy of your personal data
• Rectification: Correct inaccurate or incomplete data
• Erasure: Request deletion of your data (subject to legal obligations). Where we have a legal duty to keep the invoice, we will instead pseudonymise your record as described in § 6.
• Portability: Receive your data in a machine-readable format
• Restriction: Limit how we process your data
• Object: Oppose certain processing activities
• Withdraw Consent: For consent-based processing

To exercise these rights, email us at hello@tradinginterview.com. We will respond within 30 days.

You also have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens) at autoriteitpersoonsgegevens.nl.

8. Data Security

We implement appropriate technical and organizational measures including:

• Encryption at rest (AES-256) and in transit (TLS 1.3)
• Role-based access controls with multi-factor authentication
• Regular security audits and penetration testing
• 24/7 monitoring and intrusion detection
• Incident response procedures with breach notification within 72 hours

9. Children's Privacy

Our services are not directed to individuals under 16. We do not knowingly collect personal data from children under 16. If you become aware that a child has provided us with personal data, please contact us.

10. Changes to This Policy

We may update this privacy policy to reflect changes in our practices or legal requirements. We will notify you of material changes via email or prominent notice on our Site.

Last updated: June 23, 2025