1. Data Controller

Thales Capital is the data controller for the processing of your personal data in accordance with the General Data Protection Regulation (GDPR) and Austrian data protection laws.

Contact Information

Email: info@thalescapital.de
Website: https://thalescapital.de
Data Protection Officer: info@thalescapital.de

2. Data We Collect

2.1 Personal Information

Account Information: Name, email address, username, password
Contact Information: Email address, phone number (if provided)
Profile Information: Trading preferences, experience level, goals
Communication Data: Messages, feedback, support requests

2.2 Financial Information

Payment Data: Billing address, payment method details (processed securely by third-party providers)
Subscription Information: Service level, billing history, payment status
Trading Data: Information about your trading activities and preferences (if you choose to share this)

2.3 Technical Information

Device Information: IP address, browser type, operating system, device identifiers
Usage Data: How you interact with our services, pages visited, features used
Location Data: General geographic location (country/region level)
Log Data: Server logs, error reports, performance data

2.4 Cookies and Tracking

Essential Cookies: Required for basic website functionality
Analytics Cookies: Help us understand how you use our services
Marketing Cookies: Used to deliver relevant advertisements
Preference Cookies: Remember your settings and preferences

3. Legal Basis for Processing

We process your personal data based on the following legal grounds under GDPR Article 6:

Contract Performance (Art. 6(1)(b))

To provide our Services and fulfill our contractual obligations, including:

Delivering Smart Money Signals
Providing educational content and courses
Processing payments and subscriptions
Customer support and communication

Legitimate Interests (Art. 6(1)(f))

To improve our Services and ensure security, including:

Service improvement and development
Fraud prevention and security
Analytics and performance monitoring
Marketing communications (with opt-out option)

Consent (Art. 6(1)(a))

For optional data processing, including:

Marketing communications
Analytics cookies
Optional profile information
Data sharing with partners

Legal Obligation (Art. 6(1)(c))

To comply with applicable laws and regulations, including:

Financial record keeping requirements
Tax reporting obligations
Regulatory compliance
Legal proceedings and investigations

4. How We Use Your Data

4.1 Service Delivery

Provide Smart Money Signals and trading insights
Deliver educational content and courses
Process payments and manage subscriptions
Send notifications and alerts
Provide customer support

4.2 Service Improvement

Analyze usage patterns and user behavior
Improve our algorithms and signal accuracy
Develop new features and services
Conduct research and analytics
Optimize user experience

4.3 Security and Compliance

Prevent fraud and unauthorized access
Ensure platform security and stability
Comply with legal and regulatory requirements
Investigate and resolve security incidents
Maintain audit trails and records

4.4 Communication

Send service-related notifications
Provide updates about our services
Respond to your inquiries and support requests
Send marketing communications (with your consent)
Share important legal or policy updates

5. Data Sharing

We do not sell your personal data. We may share your information only in the following circumstances:

Service Providers

We share data with trusted third-party service providers who assist us in operating our services:

Payment Processors: Stripe, PayPal (for payment processing)
Cloud Services: AWS, Vercel (for hosting and infrastructure)
Analytics: Google Analytics (for website analytics)
Communication: Telegram (for signal delivery)
Email Services: SendGrid, Mailchimp (for email communications)

Legal Requirements

We may disclose your information if required by law or to:

Comply with legal obligations
Respond to lawful requests from authorities
Protect our rights and property
Prevent fraud or illegal activities
Protect the safety of our users

Business Transfers

In the event of a merger, acquisition, or sale of assets, your data may be transferred to the new entity, subject to the same privacy protections.

6. Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes outlined in this privacy policy, unless a longer retention period is required by law.

Data Type	Retention Period	Reason
Account Information	Until account deletion or 3 years of inactivity	Service delivery and user support
Payment Data	7 years after last transaction	Financial regulations and tax requirements
Usage Data	Up to 2 years	Analytics and service improvement
Communication Data	Up to 3 years	Customer support and legal compliance
Marketing Data	Until consent withdrawn	Marketing communications

7. Your Rights Under GDPR

You have the following rights regarding your personal data:

Right of Access (Art. 15)

Request copies of your personal data and information about how it's processed.

Right to Rectification (Art. 16)

Correct inaccurate or incomplete personal data.

Right to Erasure (Art. 17)

Request deletion of your personal data in certain circumstances.

Right to Restrict Processing (Art. 18)

Limit how we process your data in certain circumstances.

Right to Data Portability (Art. 20)

Receive your data in a structured, machine-readable format.

Right to Object (Art. 21)

Object to processing based on legitimate interests or for marketing purposes.

How to Exercise Your Rights

To exercise any of these rights, please contact us at:

Email: info@thalescapital.de
Subject Line: "GDPR Rights Request"

We will respond to your request within one month. We may ask for verification of your identity before processing your request.

8. What Are Cookies

Cookies are small text files that are stored on your device when you visit our website. They help us provide you with a better experience and understand how you use our services.

Why We Use Cookies

Essential website functionality
Remember your preferences and settings
Analyze how you use our services
Improve our website performance
Provide personalized content
Ensure security and prevent fraud

9. Types of Cookies We Use

Essential Cookies (Required)

These cookies are necessary for the website to function properly and cannot be disabled.

Cookie Name	Purpose	Duration
session_id	Maintain user session	Session
csrf_token	Security protection	Session
user_preferences	Remember user settings	1 year

Analytics Cookies (Optional)

These cookies help us understand how visitors interact with our website.

Cookie Name	Purpose	Duration
_ga	Google Analytics - distinguish users	2 years
_ga_*	Google Analytics - session state	2 years
_gid	Google Analytics - distinguish users	24 hours

Marketing Cookies (Optional)

These cookies are used to deliver relevant advertisements and track marketing effectiveness.

Cookie Name	Purpose	Duration
_fbp	Facebook Pixel - track conversions	3 months
_gcl_au	Google Ads - conversion tracking	3 months

10. Managing Cookies

You can control and manage cookies in several ways:

Browser Settings

Most browsers allow you to control cookies through their settings. You can:

Block all cookies
Block third-party cookies only
Delete existing cookies
Set preferences for specific websites

Cookie Consent

When you first visit our website, you'll see a cookie consent banner. You can:

Accept all cookies
Reject non-essential cookies
Customize your preferences
Change your settings at any time

Opt-Out Links

You can opt out of specific tracking services:

Google Analytics: Google Analytics Opt-out
Facebook: Facebook Ad Preferences
Google Ads: Google Ad Settings

Note: Disabling certain cookies may affect the functionality of our website and your user experience. Essential cookies cannot be disabled as they are necessary for the website to function properly.

11. Third-Party Cookies

We use third-party services that may set their own cookies. These services help us provide better functionality and analytics:

Google Analytics

We use Google Analytics to understand how visitors use our website. Google Analytics uses cookies to collect information about your use of our website.

Purpose: Website analytics and performance monitoring
Data Collected: Pages visited, time spent, traffic sources
Privacy Policy: Google Privacy Policy
Opt-out: Google Analytics Opt-out

Payment Processors

We use Stripe and PayPal for payment processing. These services may set cookies for security and fraud prevention.

Stripe: Stripe Privacy Policy
PayPal: PayPal Privacy Policy

Social Media

We may use social media plugins that can set cookies when you interact with them.

12. Contact Information

If you have any questions about this Privacy Policy or our data practices, please contact us:

Data Protection Contact

Email: info@thalescapital.de
Website: https://thalescapital.de
Data Protection Officer: info@thalescapital.de

We will respond to all inquiries within 48 hours during business days. For urgent data protection matters, please mark your email as "URGENT - Data Protection".

Supervisory Authority

You have the right to lodge a complaint with the Austrian Data Protection Authority (DSB) if you believe your data protection rights have been violated:

Website: www.dsb.gv.at
Email: dsb@dsb.gv.at
Address: Barichgasse 40-42, 1030 Vienna, Austria

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