Privacy Policy

This summary provides key points from our Privacy Notice, but you can find out more details about any of these topics by clicking the link following each key point or by using our table of contents below to find the section you are looking for.

• What personal information do we process? When you visit, use, or navigate our Services, we may process personal information depending on how you interact with us and the Services, the choices you make, and the products and features you use.
• Do we process any sensitive personal information? We do not process sensitive personal information.
• Do we collect any information from third parties? We do not collect any information from third parties.
• How do we process your information? We process your information to provide, improve, and administer our Services, communicate with you, for security and fraud prevention, and to comply with law. We may also process your information for other purposes with your consent. We process your information only when we have a valid legal reason to do so.
• In what situations and with which parties do we share personal information? We may share information in specific situations, such as with service providers who assist in delivering our Services, or in connection with a business transfer. We do not share personal information with third parties for their own marketing or promotional purposes.
• What are your rights? Depending on where you are located geographically, the applicable privacy law may mean you have certain rights regarding your personal information.
• How do you exercise your rights? The easiest way to exercise your rights is by submitting a data subject access request, or by contacting us. We will consider and act upon any request in accordance with applicable data protection laws.

1. What Information Do We Collect?
2. SMS Text Messaging and Opt-In
3. Cookies and Tracking Technologies
4. How Do We Process Your Information?
5. What Legal Bases Do We Rely On To Process Your Personal Information?
6. When And With Whom Do We Share Your Personal Information?
7. How Long Do We Keep Your Information?
8. How Do We Keep Your Information Safe?
9. Do We Collect Information From Minors?
10. What Are Your Privacy Rights?
11. Controls For Do-Not-Track Features
12. Do United States Residents Have Specific Privacy Rights?
13. Do We Make Updates To This Notice?
14. How Can You Contact Us About This Notice?
15. How Can You Review, Update, Or Delete The Data We Collect From You?

Personal information you disclose to us

In Short: We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services, or otherwise when you contact us.

Personal Information Provided by You. The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make, and the products and features you use. The personal information we collect may include the following:

• names
• phone numbers
• email addresses

Sensitive Information. We do not process sensitive information.

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use, or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services, and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

The information we collect includes:

• Log and Usage Data. Log and usage data is service-related, diagnostic, usage, and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type, and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches, and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called "crash dumps"), and hardware settings).

In Short: We may send you SMS messages if you opt in. You can opt out at any time by replying STOP.

TRLSTRADING LTD offers an SMS text messaging program to provide waitlist updates, enrollment notifications, appointment reminders, and, with your separate consent, marketing and promotional communications.

How You Opt In

You opt in to receive SMS messages by providing your phone number and checking the applicable consent checkbox(es) on our waitlist or sign-up form. By opting in, you confirm that you are the owner or authorized user of the mobile device associated with the phone number provided and that you agree to receive text messages from TRLSTRADING LTD at that number.

Your opt-in consent is specific to TRLSTRADING LTD and will not be shared with or sold to any third parties, except as necessary to facilitate the delivery of SMS messages through our messaging platform provider(s) and their aggregators.

Types of Messages

Depending on which consent(s) you provide, you may receive:

• Transactional messages: waitlist status updates, enrollment notifications, appointment reminders, and account-related communications.
• Marketing messages (only with separate opt-in): promotional offers, event invitations, and program announcements.

Message Frequency

Message frequency varies based on your interactions with our Services and program activity. You will not receive more messages than are reasonably necessary for the purposes described above.

Message and Data Rates

Standard message and data rates may apply, as determined by your wireless carrier and mobile plan. TRLSTRADING LTD is not responsible for any fees charged by your carrier.

Opting Out

You may opt out of receiving SMS messages at any time by replying STOP to any message you receive from us. Upon receiving your opt-out request, you will receive a one-time confirmation message, and no further SMS messages will be sent to you unless you re-subscribe.

Help

For assistance with our SMS program, reply HELP to any message or contact us at sam@trlsmentorship.com or +35794341627.

No Sharing of SMS Opt-In Data

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Text messaging originator opt-in data and consent will not be shared with any third parties, excluding aggregators and providers of the text messaging services.

In Short: We may use cookies and similar technologies to collect and store information when you visit our Services.

What Are Cookies?

Cookies are small text files placed on your device by a website or application. They help us recognize your browser, remember your preferences, and understand how you use our Services. We may also use similar technologies such as web beacons (pixel tags), local storage, and scripts that collect and track information to improve and analyze our Services.

Types of Cookies We Use

• Strictly Necessary Cookies. These cookies are essential for the operation of our Services. They enable core functionality such as page navigation, access to secure areas, and form submissions. The Services cannot function properly without these cookies, and they cannot be disabled.
• Analytics and Performance Cookies. These cookies help us understand how visitors interact with our Services by collecting information about pages visited, time spent, and any error messages encountered. We use this information in aggregate to improve how our Services work. We may use third-party analytics tools such as Google Analytics or similar services to collect this data.
• Functional Cookies. These cookies enable enhanced functionality and personalization, such as remembering your preferences or settings. If you do not allow these cookies, some features may not function as intended.

Third-Party Tracking

Our Services may contain content or integrations from third parties (such as embedded forms, analytics scripts, or social media widgets) that may set their own cookies or collect information about your activity. We do not control these third-party technologies and encourage you to review their respective privacy policies.

How to Manage Cookies

Most web browsers allow you to control cookies through their settings. You can set your browser to refuse all cookies, accept only certain cookies, or notify you when a cookie is being set. Please note that disabling cookies may affect the functionality of our Services.

For more information on managing cookies in your browser:

• Chrome: chrome://settings/cookies
• Firefox: about:preferences#privacy
• Safari: Preferences > Privacy
• Edge: Settings > Cookies and site permissions

Do Not Track

At this time, we do not respond to Do Not Track (DNT) browser signals, as no uniform standard for interpreting these signals has been established. If a standard is adopted in the future, we will update this Privacy Notice accordingly.

In Short: We process your information to provide, improve, and administer our Services, communicate with you, send you SMS messages you have opted in to receive, for security and fraud prevention, and to comply with law.

We process your personal information for a variety of reasons, depending on how you interact with our Services, including:

• To process your enquiries and applications. We process your personal information when you submit a waitlist application, contact form, or other enquiry through our website, in order to review your submission, respond to you, and determine eligibility for our educational programmes.
• To communicate with you about our Services. We may process your personal information to send you information about our trading education programmes, respond to your questions, and provide customer support. This includes communications by email and, where you have opted in, by SMS text message.
• To send you SMS text messages you have consented to receive. Where you have provided your phone number and opted in via the applicable consent checkbox on our website, we process your phone number to send you the categories of text messages described in Section 2 of this Privacy Notice, including transactional messages (waitlist updates, enrollment notifications, appointment reminders) and, where you have provided separate consent, marketing and promotional messages.
• To deliver our educational services. If you enrol in one of our programmes, we process your personal information as necessary to provide the educational services you have contracted for, including scheduling calls, granting access to programme materials, and facilitating your participation in our student community.
• To send you marketing communications (with your consent). With your consent, we may process your personal information to send you information about our programmes, events, and educational content that we believe may be of interest to you. You can withdraw your marketing consent at any time.
• To improve and optimise our Services. We may process your personal information to understand how our website is used, identify areas for improvement, and enhance the user experience. This processing is based on aggregated and anonymised data where possible.
• To ensure security and prevent fraud. We may process your personal information as necessary to protect our Services, detect and prevent fraudulent activity, and ensure the security of our systems and users.
• To comply with legal obligations. We may process your personal information where we believe it is necessary for compliance with our legal obligations, such as responding to lawful requests from public authorities, cooperating with regulatory agencies, or exercising or defending our legal rights.
• To save or protect an individual's vital interest. We may process your information when necessary to save or protect an individual's vital interest, such as to prevent harm.

In Short: We only process your personal information when we believe it is necessary and we have a valid legal reason (i.e., legal basis) to do so under applicable law, like with your consent, to fulfil our contractual obligations, to comply with laws, to protect your rights, or to fulfil our legitimate business interests.

If you are located in the EU or UK, this section applies to you.

The General Data Protection Regulation (GDPR) and UK GDPR require us to explain the valid legal bases we rely on in order to process your personal information. As such, we may rely on the following legal bases to process your personal information:

• Consent. We may process your information if you have given us permission (i.e., consent) to use your personal information for a specific purpose. This includes your consent to receive SMS text messages and your consent to receive marketing communications. You can withdraw your consent at any time.
• Performance of a Contract. We may process your personal information where it is necessary for the performance of a contract to which you are a party, or in order to take steps at your request prior to entering into a contract. For example, we rely on this basis when processing your information to deliver the educational services you have enrolled in, to schedule and conduct mentorship calls, or to provide access to programme materials.
• Legitimate Interests. We may process your information where it is necessary for our legitimate interests, provided those interests are not overridden by your rights and freedoms. Our legitimate interests include operating and improving our Services, ensuring the security of our website and systems, understanding how our Services are used, and communicating with you about our educational programmes where you have an existing relationship with us or have made an enquiry.
• Legal Obligations. We may process your information where we believe it is necessary for compliance with our legal obligations, such as to cooperate with a law enforcement body or regulatory agency, exercise or defend our legal rights, or disclose your information as evidence in litigation in which we are involved.
• Vital Interests. We may process your information where we believe it is necessary to protect your vital interests or the vital interests of a third party, such as situations involving potential threats to the safety of any person.

If you are located in Canada, this section applies to you.

We may process your information if you have given us specific permission (i.e., express consent) to use your personal information for a specific purpose, or in situations where your permission can be inferred (i.e., implied consent). You can withdraw your consent at any time.

In some exceptional cases, we may be legally permitted under applicable law to process your information without your consent, including, for example:

• If collection is clearly in the interests of an individual and consent cannot be obtained in a timely way
• For investigations and fraud detection and prevention
• For business transactions provided certain conditions are met
• If it is contained in a witness statement and the collection is necessary to assess, process, or settle an insurance claim
• For identifying injured, ill, or deceased persons and communicating with next of kin
• If we have reasonable grounds to believe an individual has been, is, or may be victim of financial abuse
• If it is reasonable to expect collection and use with consent would compromise the availability or the accuracy of the information and the collection is reasonable for purposes related to investigating a breach of an agreement or a contravention of the laws of Canada or a province
• If disclosure is required to comply with a subpoena, warrant, court order, or rules of the court relating to the production of records
• If it was produced by an individual in the course of their employment, business, or profession and the collection is consistent with the purposes for which the information was produced
• If the collection is solely for journalistic, artistic, or literary purposes
• If the information is publicly available and is specified by the regulations

We may disclose de-identified information for approved research or statistics projects, subject to ethics oversight and confidentiality commitments.

In Short: We may share information in specific situations described in this section.

We may need to share your personal information in the following situations:

• Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
• Service Providers. We may share your personal information with third-party service providers who perform services on our behalf, such as messaging platform providers, payment processors, hosting providers, and analytics services. These service providers are contractually obligated to use your personal information only for the purposes of providing services to us and in accordance with this Privacy Notice.

We do not sell, rent, or share your personal information with third parties for their own marketing or promotional purposes.

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this Privacy Notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Notice, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

SMS opt-in and opt-out records. We retain records of your SMS opt-in consent and any opt-out requests for a minimum of ten (10) years, or such longer period as may be required by applicable law, in order to comply with US state data protection requirements and to demonstrate compliance with applicable messaging regulations. These records include the date and method of consent, the phone number associated with the consent, and the date and method of any opt-out request.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

In Short: We implement reasonable technical and organizational measures to protect your personal information, but no system is 100% secure.

We take the security of your personal information seriously and have implemented commercially reasonable technical and organizational security measures designed to protect the personal information we collect and store from unauthorized access, disclosure, alteration, destruction, or loss. These measures include:

• Encryption. Personal information transmitted to and from our Services is protected using industry-standard encryption protocols (such as TLS/SSL) during transmission.
• Access Controls. Access to personal information within our organization is restricted to authorized personnel who require such access to perform their job functions. These individuals are subject to confidentiality obligations.
• Secure Infrastructure. Our Services are hosted on infrastructure provided by reputable third-party hosting and platform providers that maintain their own security certifications and compliance standards.
• Data Minimization. We only collect the personal information that is reasonably necessary for the purposes described in this Privacy Notice. We do not collect or store sensitive personal information such as Social Security numbers, financial account numbers, or government-issued identification numbers.
• Incident Response. In the event of a data breach that affects your personal information, we will notify affected individuals and relevant authorities in accordance with applicable law. You agree to notify us immediately at sam@trlsmentorship.com if you believe your information associated with our Services has been compromised.

Despite our efforts, no electronic transmission over the Internet or data storage method can be guaranteed to be 100% secure. While we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. We encourage you to take steps to protect your own personal information, such as choosing strong passwords and keeping your login credentials confidential.

In Short: We do not knowingly collect data from or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction.

We do not knowingly collect, solicit data from, or market to children under 18 years of age or the equivalent age as specified by law in your jurisdiction, nor do we knowingly sell such personal information. By using the Services, you represent that you are at least 18 or the equivalent age as specified by law in your jurisdiction or that you are the parent or guardian of such a minor and consent to such minor dependent's use of the Services. If we learn that personal information from users less than 18 years of age or the equivalent age as specified by law in your jurisdiction has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any data we may have collected from children under age 18 or the equivalent age as specified by law in your jurisdiction, please contact us at sam@trlsmentorship.com.

In Short: Depending on your state of residence in the US or in some regions, such as the European Economic Area (EEA), United Kingdom (UK), Switzerland, and Canada, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time, depending on your country, province, or state of residence.

In some regions (like the EEA, UK, Switzerland, and Canada), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; (iv) if applicable, to data portability; and (v) not to be subject to automated decision-making. If a decision that produces legal or similarly significant effects is made solely by automated means, we will inform you, explain the main factors, and offer a simple way to request human review. In certain circumstances, you may also have the right to object to the processing of your personal information. You can make such a request by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

We will consider and act upon any request in accordance with applicable data protection laws.

If you are located in the EEA or UK and you believe we are unlawfully processing your personal information, you also have the right to complain to your Member State data protection authority or UK data protection authority.

If you are located in Switzerland, you may contact the Federal Data Protection and Information Commissioner.

Withdrawing your consent: If we are relying on your consent to process your personal information, which may be express and/or implied consent depending on the applicable law, you have the right to withdraw your consent at any time. You can withdraw your consent at any time by contacting us by using the contact details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below.

However, please note that this will not affect the lawfulness of the processing before its withdrawal nor, when applicable law allows, will it affect the processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opting out of marketing and promotional communications: You can unsubscribe from our marketing and promotional communications at any time by replying "STOP" or "UNSUBSCRIBE" to the SMS messages that we send, or by contacting us using the details provided in the section "HOW CAN YOU CONTACT US ABOUT THIS NOTICE?" below. You will then be removed from the marketing lists. However, we may still communicate with you — for example, to send you service-related messages that are necessary for the administration and use of your account, to respond to service requests, or for other non-marketing purposes.

No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. Information sharing to subcontractors in support services, such as customer service, is permitted. All other use case categories exclude text messaging originator opt-in data and consent; this information will not be shared with third parties.

If you have questions or comments about your privacy rights, you may email us at sam@trlsmentorship.com.

Most web browsers and some mobile operating systems and mobile applications include a Do-Not-Track ("DNT") feature or setting you can activate to signal your privacy preference not to have data about your online browsing activities monitored and collected. At this stage, no uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Notice.

California law requires us to let you know how we respond to web browser DNT signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time.

In Short: If you are a resident of California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the right to request access to and receive details about the personal information we maintain about you and how we have processed it, correct inaccuracies, get a copy of, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law.

Categories of Personal Information We Collect

We have collected the following categories of personal information in the past twelve (12) months:

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

Sources of Personal Information

Learn more about the sources of personal information we collect in "WHAT INFORMATION DO WE COLLECT?"

How We Use and Share Personal Information

Learn more about how we use your personal information in the section, "HOW DO WE PROCESS YOUR INFORMATION?"

Will your information be shared with anyone else? We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. Learn more about how we disclose personal information in the section, "WHEN AND WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?"

We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be "selling" of your personal information.

We have not disclosed, sold, or shared any personal information to third parties for a business or commercial purpose in the preceding twelve (12) months. We will not sell or share personal information in the future belonging to website visitors, users, and other consumers.

Your Rights

You have rights under certain US state data protection laws. However, these rights are not absolute, and in certain cases, we may decline your request as permitted by law. These rights include:

• Right to know whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request the deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to non-discrimination for exercising your rights
• Right to opt out of the processing of your personal data if it is used for targeted advertising (or sharing as defined under California's privacy law), the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects ("profiling")

Depending upon the state where you live, you may also have the following rights:

• Right to access the categories of personal data being processed (as permitted by applicable law, including the privacy law in Minnesota)
• Right to obtain a list of the categories of third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in California, Delaware, and Maryland)
• Right to obtain a list of specific third parties to which we have disclosed personal data (as permitted by applicable law, including the privacy law in Minnesota and Oregon)
• Right to obtain a list of third parties to which we have sold personal data (as permitted by applicable law, including the privacy law in Connecticut)
• Right to review, understand, question, and depending on where you live, correct how personal data has been profiled (as permitted by applicable law, including the privacy law in Connecticut and Minnesota)
• Right to limit use and disclosure of sensitive personal data (as permitted by applicable law, including the privacy law in California)
• Right to opt out of the collection of sensitive data and personal data collected through the operation of a voice or facial recognition feature (as permitted by applicable law, including the privacy law in Florida)

How to Exercise Your Rights

To exercise these rights, you can contact us by submitting a data subject access request, by emailing us at sam@trlsmentorship.com, or by referring to the contact details at the bottom of this document.

Under certain US state data protection laws, you can designate an authorized agent to make a request on your behalf. We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with applicable laws.

Request Verification

Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have the information in our system. We will only use personal information provided in your request to verify your identity or authority to make the request. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes.

If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request and the agent will need to provide a written and signed permission from you to submit such request on your behalf.

Appeals

Under certain US state data protection laws, if we decline to take action regarding your request, you may appeal our decision by emailing us at sam@trlsmentorship.com. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may submit a complaint to your state attorney general.

In Short: Yes, we will update this notice as necessary to stay compliant with relevant laws.

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date at the top of this Privacy Notice. If we make material changes to this Privacy Notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this Privacy Notice frequently to be informed of how we are protecting your information.

If you have questions or comments about this notice, you may email us at sam@trlsmentorship.com or contact us by post at:

Based on the applicable laws of your country or state of residence in the US, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. You may also have the right to withdraw your consent to our processing of your personal information. These rights may be limited in some circumstances by applicable law. To request to review, update, or delete your personal information, please fill out and submit a data subject access request.