privacy + cookies policy
Humbled Trader Inc., is a British Columbia corporation having its head offices at 25th Floor, 700 West Georgia Street Vancouver, BC V7Y 1B3 CANADA. This Privacy Policy (“Policy”) describes the personal information that Humbled Trader Inc. (“HT”, “we” or “us”) collects from or about you when you use the humbledtrader.com website (the “Site”), purchase or use our products or services, or otherwise interact with us. It also describes how we use that information, and to whom we disclose it. As used in this Policy, “personal information” means information about an identifiable individual. This Policy should be read in conjunction with the Site’s Terms of Use: https://www.humbledtrader.com/terms-conditions
Please read this Policy carefully and contact us if you have any questions. By using our Site, other than to review this Policy and the Site’s Terms of Use, you will be deemed to have agreed to this Policy. If you do not agree with this Policy, you should not access or use the Site or our materials.
This Policy was last updated on Aug 27, 2021. HT reserves the right to revise this Policy from time to time and, as such, you should review its terms each time that you visit our Site. We will notify you about any significant changes in the way we handle personal information by sending a notice to the primary email address specified in your account, by placing a prominent notice on the Site, and/or by updating the privacy information on this page. Any changes to this Policy will not go into effect until at least five (5) days after they are posted or otherwise communicated to you.
Accountability and Openness / Privacy Officer
Protecting your personal information is our priority. HT is responsible for personal information under our control, and we are accountable to you for our collection, use and disclosure if it. We have established policies and procedures to safeguard any personal information that we have on file or that we collect, and to deal with complaints and inquiries. We will only collect personal information as described in this Policy.
HT has designated a chief privacy officer (the “Privacy Officer”) who is accountable for the protection of data containing personal information, and for our compliance with this Policy.
If you have questions or concerns regarding this Policy, our compliance with it, as well as any of our processes and procedures relating to the collection, use and disclosure of your personal information, you may direct them in writing to the Privacy Officer at admin[at]humbledtrader.com
Collection of Information
What Information is Collected and How?
We collect personal information only to the extent that it is necessary for the purposes set out below (see: Purpose - Why We Collect, Use and Disclose Information). In most cases, we will collect personal information directly from you when you visit the Site or interact with us with respect to our products or services. Personal information will always be collected using means that are transparent, fair and lawful.
A. Direct Collection
Examples of personal information that we may collect, use and disclose include your name, email address and telephone number. If you purchase HT’s products and services, we will also collect billing and credit card information. This information will only be collected when you voluntarily provide it to us.
If you provide comments or other feedback to us regarding our products or services, such comments or other feedback become the property of HT and we may use, disclose and share them for any purpose provided that we do not associate them with your personal information without your express consent.
B. Information Collected Through Automated Means
Users may visit the Site without telling us who they are or revealing any information about themselves. However, like many companies’ websites, our web server automatically logs certain information related to a user’s visit to the Site, including the Internet Protocol (IP) address of the user’s computer, the user’s Internet service provider (ISP), the type and version of the browser that the user is using, the date and time the user accessed the Site, the Internet address of the website from which the user linked directly to the Site, the operating system that the user is using, and the pages of the Site that the user has visited. Unless required or permitted by law, we will not attempt to link this information with the identity of individuals visiting our Site unless we have consent to do so. We may, however, review server logs and traffic for system administration and security purposes, for example to detect intrusions into our network, for planning and improving our website and product offerings, and to monitor and compile statistics about website usage. The possibility therefore exists that server log data, which contains users’ IP addresses, could in instances of criminal malfeasance be used to trace and identify individuals. In such instances, we may share raw data logs with the appropriate authorities for the purpose of investigating security breaches.
Cookies: We use “cookies” in order to improve your user experience, and to analyze how the Site is used. This allows us to determine which HT services are the most popular, and to deliver customized content and advertising to users whose behavior indicates that they are interested in a particular subject area.
Cookies are small text files that are placed on your computer by websites that you visit. They are used to identify you to the web server, and will tell the server who you are when you return to a page on the same website. Your browser will only send a cookie back to the domain that originally sent it to you. A cookie cannot run any programs, deliver any viruses, or send back information about your system. There are different types of cookies: Session cookies expire when you close your browser; persistent cookies remain on your device until they are deleted or expire.
We use cookies:
to personalize your online experience;
to save you time and facilitate browsing, by recalling your specific information and preferences on subsequent visits to the Site;
to determine and authenticate your access privileges on our Site;
to complete and support a current activity;
to track website usage;
to implement security features;
for advertising purposes, to offer you relevant targeted offers and other content that may be of interest to you; and
to generally improve your online user experience.
When you first visit the Site, a pop-up banner informs you of the use of cookies, seeks your express consent to their use, and provides a direct link to this information page. Although the banner will not normally appear on subsequent visits to the Site, you may withdraw your consent to the use of cookies at any time by following the instructions below.
Most web browsers automatically accept cookies, but if you do not wish to have cookies on your system, you should adjust your browser settings to decline them or to alert you when cookies are being sent. The management of cookies varies for each browser, and you should consult the “Help” menu of your browser.
If you decline cookies, you may still be able to use the Site but your ability to access certain pages, features and functions may be affected. To find out more about cookies, including how to see what cookies have been set and how to manage and remove them, please visit AboutCookies.org or All_About_Cookies.org.
Google Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about the use of our website, and to report on activities, trends and user behavior patterns. We do this to obtain an overview of how people are accessing and using the Site, as well as to provide marketing services to you. Information that we use from Google Analytics includes: IP address; time per page; pages per session; bounce rate; device information; browser and operating systems; network; frequency of use; language; demographic; and geographic. You can learn about Google’s practices by going to www.google.com/policies/privacy/partners. You can opt out by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout
Squarespace. Our data is hosted on the Squarespace platform. Squarespace Inc. collects information about your interactions with us, although they use this in an anonymous, aggregated or pseudonymized form which does not focus on you individually. This data is used to evaluate, provide, protect or improve Squarespace’s services (including by developing new products and services). Squarespace may also share data with us regarding your use of our Site, so that we may analyze the use of our Site and improve our Services. Squarespace’s privacy policy may be found at https://squarespace.com/privacy
Consent
Consent for the collection, use or disclosure of personal information may be expressed or implied. Typically, where we rely on consent to process your personal information, we will seek your consent at the time of collection, and efforts will be made to ensure that you understand the purpose(s) for which the information will be used or disclosed. In certain circumstances, we might seek your consent regarding use or disclosure after the information has been collected, but before use, such as when HT wishes to use personal information already in its possession for a purpose that was not previously identified.
Part of providing meaningful consent is understanding the risk of harm and other consequences of the disclosure of your personal information. While we endeavour to continually use best practices to minimize the risk of harm (See: Safeguards – How Personal Information is Protected, below), technology is constantly evolving and no safeguards can be guaranteed to be failsafe or to provide absolute protection against malfeasors. Significant harm that may result from the unauthorized use of the personal information that you disclose to us includes identity theft and credit card fraud.
Withdrawal of consent
You may always choose not to disclose personal information. Also, when we are already using your personal information on the basis of your consent, you may withdraw or change your consent at any time. To withdraw or change your consent to our use of your personal information, please send your request in writing, along with details of the use of your information that you wish to change or withdraw your consent for, to the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer).
In some circumstances, particularly where our use of your information is integral to the provision of a product or service, your refusal to provide consent, or a change or withdrawal of consent, may adversely affect your interactions with us and/or our ability to provide you with information, products or services.
Purpose - Why We Collect, Use and Disclose Information
We will not collect personal information which is not necessary and, except as specified below, will not use or disclose personal information for any purpose other than the purpose(s) for which it was collected, without first obtaining your consent. The information that we collect is used and disclosed only for business purposes. These include:
to operate and maintain the Site, and to respond to your requests, questions and concerns;
to create a user account for you;
to process payments, credits and refunds;
to make our products and services available to you;
to support our advertising and marketing activities, including informing you of products, services and promotions that we offer or that are offered by our selected third party partners, and to enable you to participate in sweepstakes and contests;
to provide you with personalized content, and to maximize our ability to provide you with information and services that are useful and relevant to you;
to obtain feedback regarding our products and services, which may include inviting you by email to write a review of our videos and other course materials. This allows us to continually improve the materials that we offer;
to verify that any information submitted by you is accurate and complete;
to generally communicate with you for reasons related to our business, such as to provide you with announcements, updates, alerts, confirmations, corrections and surveys;
to create a record of your involvement with us;
for legal purposes, which may include the handling and resolution of claims and legal disputes, or for regulatory investigations and compliance;
to detect and prevent error, fraud, theft and other illegal or unwanted activities;
internal business purposes, including data analysis, to administer or improve our services, enhance the user experience, and to improve the functionality and quality of our Site and online materials;
to comply with any legal, accounting and regulatory requirements, including reporting requirements; and
any other reasonable purpose for which you provide consent, or for which consent may be implied in accordance with this Policy and applicable law.
Where personal information that has been collected is to be used for a purpose not previously identified, we will notify you of the new purpose and, where necessary, obtain your consent, prior to the use of that information for the new purpose unless otherwise permitted by law.
Commercial Electronic Messages
We comply with Canadian “anti-spam” legislation, and will only send you electronic communications as permitted by law. Note that you may always unsubscribe from our electronic communications by following the “unsubscribe” link clearly included in each communication, or by notifying the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer). We will promptly comply with all unsubscribe requests.
Disclosure to Third Parties
Except as specifically provided in this Policy or permitted by law, your personal information will not be shared with third parties unless we provide you with both prior notice and choice. HT does not sell, rent or lease its customer lists to third parties.
From time to time, HT may disclose your personal information to third party subcontractors in connection the operation of our business, and the provision to you of our products and services. Third party subcontractors to which we may disclose your personal information may include payment processors, login authentication services, analytical support services, web hosts, and parties that we engage to send out marketing materials.
We have contracts in place with our subcontractors to ensure that they keep your personal information safe, secure, confidential, and in line with this Policy and applicable laws. In all cases, we will provide the subcontractors only with the information needed to perform the subcontracted service. Details regarding the personal information that we make available to our third party subcontractors, and how it is used, is available by contacting the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer). Any request made by you to correct, change or erase your personal information will be promptly communicated to any third party subcontractors in possession of that information (see: Individual Access / Accuracy / Erasure).
We may collect, use or disclose your personal information without your knowledge or consent where we are permitted or required to do so by applicable law, government request, request of a law enforcement agency, search warrant, subpoena or court order, or based upon our good faith belief that it is necessary to do so in order to comply with such law, request, warrant, subpoena or court order, or to enforce our rights or to protect our assets, the users of the Site, or the public.
We may transfer to another entity, or its affiliates or service providers, some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. In each such case, HT and the other party(ies) to the transaction or proposed transaction will enter into a written agreement limiting the period and purposes for which your personal information may be used and disclosed.
Retention of Personal Information
Subject to any legal or accounting requirements, we will retain personal information only as long as necessary to fulfill the purposes for which it was collected. Personal information that is no longer required will be destroyed, erased or made anonymous, although copies of deleted information may continue to exist on back-up media. In certain circumstances, you may request the erasure of your personal information, which we will endeavor to do without undue delay as required by applicable law. Written requests should be sent to the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer). Any third party subcontractors to which we disclose your personal information (see: Disclosure to Third Parties) must return or destroy the information when it is no longer required for the purpose of the subcontracted services.
Safeguards – How Personal Information is Protected
We have implemented physical, organizational, contractual and technological security measures to protect personal information in our possession or under our control from loss or theft, and from unauthorized access, disclosure, copying, use or modification, regardless of the format in which the information is held. The safeguards applied will depend on the sensitivity of the personal information, with the highest level of protection given to the most sensitive information. Our data systems use user IDs, passwords, and encryption technology. We only store data on remote servers hosted by reputable companies. Staff and contractors who have access to personal information are bound by confidentiality obligations in order to ensure that information is handled and stored in a confidential and secure manner. Any credit card information that you submit will not be stored on our servers. Personal information that is transmitted to other sites is protected through the use of encryption, such as Secure Sockets Layer (SSL) protocol. When destroying personal information, we delete electronically stored personal information and shred any physical materials containing personal information. While we will endeavour to destroy all copies of personal information, you acknowledge that deleted information may continue to exist on back-up media but will not be used unless permitted by law.
We will continually review and update our security policies and controls as technology evolves. However, no security technology can be guaranteed to be failsafe. Using the Internet or other public means of communication to collect and process personal information may involve the transmission of data on an international basis and across networks not owned and/or controlled by HT. Accordingly, we cannot guarantee that personal information will not be lost, or that it will not be altered, intercepted or stored by an unauthorized third party.
Individual Access / Accuracy / Destruction
We will endeavour to ensure that personal information contained in our records or which is disclosed to third parties for the purposes described above will be as accurate, complete and up-to-date as is necessary for the purposes for which it is used. You may request access to the personal information that we hold about you by submitting a written request to the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer). Including “Request personal information” in the subject line of your email or letter will facilitate compliance with your request. We will inform you of your personal information held by us, and provide an account of the use that has been made of the information, as well as identify any third parties to whom we have disclosed the information. In some instances, you may also be entitled to receive a copy of your personal information in a structured, commonly-use, machine-readable format (or request that this be transferred to a third party where technically possible). In certain circumstances, HT may not be able to provide you with access to all or some of your personal information, in which case you will be advised in writing of the reasons for our inability to provide you with the information.
You also have the right to request that we correct or rectify any information that we hold about you which is out of date or incorrect. If you demonstrate the inaccuracy or incompleteness of your personal information, the information will be amended as appropriate. You should advise us immediately if you discover inaccuracies in our data or if your personal information changes. All notices and requests regarding inaccuracies or changes should be in writing and sent to the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer).
In certain circumstances, you have the right to require that we erase, limit, or cease processing your personal information. All notices and requests asking us to erase, limit or stop processing your personal information should be in writing and sent to the Privacy Officer at the address set out above (see: Accountability and Openness / Privacy Officer).
Links to other Websites
The Site contains optional links to third party Internet sites that we believe may be of interest to you. Those links are provided for your convenience only, and HT does not provide or endorse any information, goods or services available through those sites. If you click on those links, you will leave the HT website, and third parties may collect personal information from you or your electronic devices in connection with your visit to their websites. The accessing and use of any third party websites is at your own risk, and we cannot assume responsibility for the privacy practices, policies or actions of the third parties who operate those websites. This Policy applies only to HT websites, and we encourage you to review the privacy policies contained on each Internet site that you access.
International Transfer and Storage of Information
HT is based in Canada. However, our Site and your personal information is hosted by our third party service providers, and may be transmitted, transferred, processed, backed-up, used and/or stored outside of Canada, including in the United States and Europe (see: Disclosure to Third Parties). We will use reasonable means to ensure that your information is protected, including written agreements with our third party subcontractors, but cannot guarantee that the laws of any foreign jurisdiction will accord the same degree of protection as the laws of Canada.
Minors
Minors may only use the Site with the express permission of a parent or guardian. HT will never knowingly collect personal information from minors without a parent or guardian’s express consent, and will only do so when necessary in connection with the use of the Site or our products and services in accordance with that consent. If we are advised or otherwise discover that personal information has been collected from a minor without the express consent of a parent or guardian, we will take all commercially reasonable steps to delete that information.
Compliance and Governing Law
Inquiries, requests and complaints regarding our compliance with this Policy should be directed to the Privacy Officer (see: Accountability and Openness / Privacy Officer).
Every complaint or challenge regarding our compliance with this Policy will be investigated, and where a deficiency is found to exist, we will take appropriate measures to address it. This may include amending our policies and procedures as necessary. We will also cooperate with regulatory authorities to resolve any complaints that cannot be resolved between us and an individual.
The humbledtrader.com is operated from Vancouver, British Columbia, Canada. Except as required by applicable privacy laws, your use of the Site, this Policy and the protection of your personal information will be governed exclusively by the applicable laws of the Province of British Columbia and of Canada.