This Privacy Policy (the “Policy”) describes how Trading Education OÜ, a private limited company incorporated under the laws of the Republic of Estonia, with its registered office at Harju maakond, Tallinn, Lasnamäe linnaosa, Tähesaju tee 21-114, 13917 (the “Company”, “we”, “us”), acting as a data controller, collects, uses, processes, stores, and protects personal data of individuals who access our Telegram bot, Telegram channels, Zoom sessions, website (if applicable), or otherwise interact with our digital informational services (collectively, the “Services”).

This Policy applies to personal data collected through Telegram, Zoom, our website (if applicable), payment systems, communication channels, forms, and other digital touchpoints related to the Services.

By accessing the Telegram bot, Telegram channels, Zoom sessions, Website, submitting forms, registering an account, or otherwise interacting with the Services, you acknowledge that you have read and understood this Policy.
If you do not agree with the terms of this Policy, please refrain from using the Services or submitting any personal data.

1. DEFINITIONS

For the purposes of this Privacy Policy, the following terms shall have the meanings set forth below:
1.1. “Platform” means the Telegram bot, Telegram channels and chats, Zoom sessions, and any website (if applicable) operated or designated by the Company through which Users access the Services.
1.2. “Company”, “we”, “us” refers to Trading Education OÜ, a private limited company incorporated in Estonia, acting as the provider of the subscription-based digital community and informational services known as “DOM KRALOVYKH”.
1.3. “Participant”, “User”, or “you” means a natural person of legal age and full legal capacity who accesses or uses the Services in accordance with the Terms and Conditions.
1.4. “Personal Data” means any information relating to an identified or identifiable natural person, including:
– Telegram usernames, Telegram IDs, email addresses, subscription status and payment identifiers;
– technical data such as IP address, device and application information, timestamps, and platform activity;
– any other information voluntarily provided or generated through use of the Services.
1.5. “Services” means the subscription-based digital community and informational service “DOM KRALOVYKH”, including access to Telegram chats and channels, Zoom sessions, digital materials, updates, and communications.
1.6. “IP address” means a unique numerical identifier assigned to a device connected to a network.
1.7. “Processing” means any operation performed on Personal Data, including collection, storage, use, disclosure, restriction, or deletion.
1.8. “Confidentiality” means the obligation to protect Personal Data and not disclose it without lawful basis.
1.9. “Controller” means Trading Education OÜ, which determines the purposes and means of processing Personal Data.
1.10. “Consent” means a freely given, informed, and unambiguous agreement to the processing of Personal Data.

2. GENERAL PROVISIONS

2.1. This Privacy Policy applies to all Personal Data collected through the Platform or otherwise in connection with your participation in the Services. The Platform includes the Company’s Telegram bot, Telegram channels and chats, Zoom sessions, website (if applicable), and all associated web pages, digital features, applications, widgets, forms, communication tools, and other interfaces that are operated, maintained, or provided by the Company and link to or reference this Policy.
2.2. The Company may collect and process your Personal Data for the purpose of delivering, maintaining, improving, and supporting the Services, as well as for ensuring legal compliance, user support, analytics, and communications consistent with this Policy.
2.3. The Company is committed to protecting the privacy and integrity of all Personal Data processed in connection with the Services. We uphold high standards of data confidentiality and transparency and aim to create a secure and respectful environment for all Users.
2.4. This Policy explains how we collect, use, disclose, and protect your Personal Data when you access the Platform or participate in the Services. This Policy does not apply to the practices of third-party websites, platforms, or entities not owned or controlled by the Company, even if linked to from the Platform.
2.5. As the data controller, Trading Education OÜ determines the purposes and means of processing your Personal Data, in accordance with applicable data protection laws, including the General Data Protection Regulation (EU) 2016/679 (“GDPR”).
2.6. Depending on the nature of the interaction and the specific processing activity, the Company processes Personal Data on one or more lawful bases under applicable data protection laws, including where necessary: (a) performance of a contract or steps taken at your request prior to entering into a contract; (b) compliance with legal obligations; (c) the Company’s legitimate interests in operating, maintaining, and improving the Services, provided such interests are not overridden by your fundamental rights and freedoms; and (d) your consent, where explicitly required by applicable law (for example, for certain marketing communications or optional data collection).

3. DATA WE COLLECT ABOUT YOU

3.1. Depending on your interaction with the Platform (Telegram, Zoom, website if applicable) and your participation in the Services, we may collect and process different categories of Personal Data, as described below.
3.1.1. Data you voluntarily provide to us when you subscribe via the Telegram bot, join Telegram chats, participate in Zoom sessions, complete forms, contact support, or otherwise communicate with the Company. This may include:
– full name (where provided);
– Telegram username and Telegram ID;
– email address (where provided);
– telephone number (where provided);
– country or city of residence;
– subscription status and payment confirmation identifiers;
– any other information you choose to provide through messages, forms, support interactions, or correspondence.
Such data is processed in accordance with this Privacy Policy and the lawful bases set out in Section 2.6.t-out mechanisms provided.
3.1.2. Technical and usage data collected automatically when you access or use the Platform, including through Telegram and Zoom, which may include:
– device and application information;
– operating system and interface settings;
– time zone and language preferences;
– IP address and general location (city-level);
– Telegram and Zoom technical identifiers;
– session activity logs and usage patterns.
3.1.3. Usage Data includes information about how you interact with Telegram chats, Zoom sessions, and digital materials, such as participation activity, access to content, and session duration.
3.1.4. Marketing and Preference Data includes your communication preferences, subscription status, opt-in and opt-out records, and interactions with informational or service-related communications.
3.1.5. Communication Data includes Telegram messages, Zoom chat messages, support tickets, emails, form submissions, and related metadatа.
3.1.6. Anonymous or pseudonymized data, which may be generated by removing or separating identifiable elements from Personal Data. Anonymous data, which cannot be used to identify an individual, may be used for analytical and statistical purposes and may be shared with third parties at the Company’s discretion. Pseudonymized data remains subject to applicable data protection laws and is processed in accordance with this Policy.
3.2. We may also process aggregated data, including statistical summaries or generalized indicators derived from multiple users. Aggregated data is not considered Personal Data under applicable law unless it is combined with other information in a manner that allows an individual to be identified. Where aggregated data is linked to an identifiable individual, it will be treated as Personal Data and processed accordingly.
3.3. The Company does not intentionally collect or process special categories of Personal Data as defined under Article 9 of the GDPR, including data relating to racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership, health data, biometric data, genetic data, or data concerning a person’s sex life or sexual orientation.

4. PERSONAL DATA COLLECTION

4.1. We collect Personal Data from Users through various sources and by the following means:
(a) Direct Interactions. You may provide Personal Data to us directly when you:
– use the Telegram bot, join Telegram chats, or participate in Zoom sessions;
– visit or browse our website (if applicable);
– register an account or submit a form;
– subscribe to the Services or any communications;
– contact our support team;
– respond to surveys, or otherwise voluntarily communicate with the Company.
(b) Automated Technologies. When you use the Platform (including Telegram and Zoom) or Services, we may automatically collect certain technical and usage-related Personal Data. This may include:
– device and application information;
– IP address and general (city-level) location data;
– session data and general usage patterns;
– Telegram and Zoom technical identifiers and logs;
– server logs and similar technical records.
Such data is collected for purposes of security, functionality, diagnostics, and service improvement.

(c) Third-Party Sources. We may receive Personal Data from third parties acting on our behalf or in connection with the Services, including:
– Telegram, Zoom, and payment service providers;
– hosting and infrastructure providers;
– communications or support platforms used to interact with Users.
We do not control the data collection practices of independent third parties, and such processing is governed by their respective privacy policies.
(d) Publicly Available Sources. In limited circumstances, we may access publicly available information where necessary for legal compliance, fraud prevention, or protection of the Company’s legitimate interests.
4.2. Personal Data is collected and processed only to the extent necessary for the purposes described in this Policy and on one or more lawful bases under Article 6(1) of the GDPR, including performance of a contract, compliance with legal obligations, legitimate interests, or consent where explicitly required by law. Submission of Personal Data does not automatically imply consent for all forms of processing.

5. PURPOSES OF PERSONAL DATA USAGE

5.1. We process your Personal Data only when there is

a valid legal basis under applicable data protection laws, including: (a) performance of a contract or steps taken at your request prior to entering into a contract;

to comply with legal and regulatory obligations;

to pursue our legitimate interests in operating, maintaining, securing, and improving the Platform and Services (provided that such interests are not overridden by your fundamental rights and freedoms);

where you have provided your explicit consent and only where such consent is required by applicable law (for example, for certain marketing communications).

5.2. Specifically, we use and may process your Personal Data for the following purposes:

to register you as a Participant and provide access to the Services;

to process payments and manage transactional records;

to deliver support, respond to inquiries, and maintain communication with you via Telegram, Zoom, or email; 

to notify you of updates to the Platform, Services, Terms of Use, or this Policy;

to collect insights on how Participants interact with the Services, in an aggregated or non-identifying manner, for product improvement and experience optimization;

to analyze general usage trends and Participant preferences for internal business analysis and service development purposes;

to administer, monitor, troubleshoot, and improve the technical performance, stability, and security of the Platform (including Telegram and Zoom);

to maintain secure backups and data recovery systems;

to share data with trusted service providers or contractors acting on our instructions and bound by data protection and confidentiality obligations;

to ensure compliance with the Terms of Use and enforce our rights;

to protect the safety, integrity, and rights of Participants, third parties, and the Company;

to comply with applicable laws, lawful requests, court orders, or regulatory requirements;

to obtain legal, accounting, or professional advice;

to establish, exercise, or defend legal claims;

to respond to legitimate law enforcement or national security requests;

for any additional purpose where you have provided explicit consent, where such consent is required by law.

5.3. Where required by applicable law, and subject to your preferences, we may use your identity, contact details, and limited technical or usage data to send you informational or promotional communications related to the Services (“marketing communications”). You may receive such communications if:

you have previously requested information or subscribed to the Services; and

you have not opted out of receiving such communications.

5.4.  Marketing Communications and Consent. Where required by applicable data protection laws, the Company processes Personal Data for the purpose of sending informational and marketing communications only on the basis of the User’s explicit and separate consent. Such consent is obtained through a clear affirmative action by the User, including but not limited to selecting a dedicated checkbox, interacting with a Telegram bot command, or otherwise expressly indicating agreement to receive marketing communications.
Marketing communications may include updates about the Services, new features, content releases, community events, offers, and other information related to the Company’s activities. The User may withdraw consent to receive marketing communications at any time, without affecting the lawfulness of processing based on consent before its withdrawal, by: (a) using the unsubscribe or opt-out mechanism provided in the relevant message; or  (b) contacting the Company via the official support channel. Withdrawal of marketing consent does not affect the User’s access to the Services or the receipt of strictly service-related or transactional communications necessary for the performance of the contract.
5.5. You may withdraw your consent to receive marketing communications at any time by contacting us at: official-support@thomaskralow.com.

6. PERSONAL DATA DISCLOSURE

6.1. We treat all Personal Data as confidential and do not disclose it to third parties except as permitted under this Privacy Policy, required by applicable law, or where disclosure is necessary for the performance of a contract, the pursuit of our legitimate interests, or compliance with legal obligations. We do not sell, rent, or trade your Personal Data to any third party. Disclosure may occur solely for purposes related to the provision, maintenance, security, and improvement of the Services.
6.2. We may disclose your Personal Data to trusted service providers, agents, subcontractors, or business partners acting on our instructions, who assist us in delivering and supporting the Services. Such third parties may include Telegram, Zoom, technical infrastructure and hosting providers, customer support platforms, payment processors, communication or messaging tools, and legal, accounting, or professional advisors. All such parties are contractually bound to process Personal Data only in accordance with our instructions, applicable data protection laws, and confidentiality obligations.
6.3. We may disclose your Personal Data where required by law, court order, or request from a competent governmental authority, or where such disclosure is necessary to enforce our Terms of Use, investigate suspected fraud or security incidents, protect the rights, property, or safety of the Company, Users, or third parties, or comply with applicable legal and regulatory requirements. In the event of a corporate transaction, such as a merger, acquisition, asset transfer, reorganization, or insolvency, your Personal Data may be transferred to a successor entity, provided that such entity remains subject to obligations consistent with this Privacy Policy and applicable data protection laws.
6.4. The Platform (including Telegram, Zoom, and any website used by the Company) may contain links to third-party services. Any interaction with such services is governed by their own privacy policies. The Company is not responsible for their data handling practices.

7. SAFETY

7.1. We are committed to maintaining the security and confidentiality of your Personal Data and have implemented appropriate technical and organizational measures to protect it against unauthorized access, alteration, disclosure, destruction, or other forms of unlawful processing in accordance with applicable data protection laws. Access to your Personal Data is strictly limited to authorized employees, contractors, or service providers who are bound by confidentiality and data protection obligations and who require such access in order to perform their designated functions.
7.2. Personal Data transmitted through the Company’s website (if applicable) is protected by SSL encryption. Data transmitted through third-party platforms used for the Services, including Telegram and Zoom, is protected in accordance with the security and encryption measures implemented by those providers under their own privacy and security policies.

If you are provided with (or choose) login credentials or access links, you are responsible for keeping them confidential.
7.3. While we implement industry-standard safeguards to protect your information, you acknowledge that no method of transmission over the Internet or method of digital storage can be completely secure. We therefore cannot guarantee absolute security of your data, although we make every reasonable effort to prevent security breaches.
7.4. Depending on the specific risks associated with the processing of your Personal Data, we may implement additional protective measures, including but not limited to: staff training and internal privacy protocols, physical access controls, encryption and pseudonymization techniques, data availability and recovery mechanisms, and regular system audits.
7.5. We also maintain procedures for detecting and responding to potential Personal Data breaches. In the event of a confirmed breach that may pose a risk to your rights and freedoms, we will promptly notify you and the relevant supervisory authority in accordance with applicable law.

8. PERSONAL DATA RETENTION

8.1. We retain your Personal Data only for as long as is reasonably necessary to fulfill the purposes for which it was collected, including to satisfy any legal, regulatory, tax, accounting, or reporting obligations. In certain circumstances, we may retain your data for a longer period, particularly where it is necessary for the establishment, exercise, or defense of legal claims, enforcement of our agreements, fraud prevention, or internal auditing purposes.
8.2. When determining the appropriate retention period, we consider the nature, volume, and sensitivity of the Personal Data, the risk of potential harm from unauthorized use or disclosure, the purposes for which we process the data and whether those purposes can be achieved through alternative means, as well as the legal requirements applicable in Estonia and the European Union.
8.3. Once your Personal Data is no longer required for the stated purposes, or when the retention period expires, we will securely delete, anonymize, or destroy such data in accordance with industry best practices and applicable data protection laws.

9. SAFETY OF MINORS

9.1. The Platform and Services are not intended for use by individuals under the age of 18 years or by persons lacking full legal capacity under applicable law. We do not knowingly collect or process Personal Data of minors. By accessing the Platform or using the Services, you confirm that you meet the applicable age requirement and have full legal capacity.
9.2. We take the protection of minors seriously and urge parents and legal guardians to educate their children about responsible online behavior and the risks associated with sharing personal information over the Internet.

9.3. If a parent or legal guardian becomes aware that a minor has provided us with Personal Data in violation of this Policy, they should contact us without delay at official-support@thomaskralow.com . Upon receiving such a request and verifying the status of the data subject, we will promptly take all reasonable steps to delete the information from our systems and prevent further processing.

10. INTERNATIONAL DATA TRANSFERS

As the Company operates internationally, your Personal Data may be transferred to and processed in jurisdictions outside your country of residence, including countries outside the European Economic Area (EEA), such as the United States, where our affiliates or service providers may be located. These jurisdictions may have data protection laws that differ from those applicable in the EEA and may not always provide an equivalent level of protection. Nevertheless, we implement appropriate and legally recognized safeguards to ensure that such international transfers comply with applicable data protection laws and that your Personal Data remains protected in accordance with this Privacy Policy. Where required by law, such safeguards may include adequacy decisions adopted by the European Commission, Standard Contractual Clauses (SCCs), or other lawful transfer mechanisms, including your explicit consent where applicable. We remain committed to maintaining a high standard of data protection regardless of the location in which your Personal Data is processed.

11. DATA SUBJECT RIGHTS – EUROPEAN UNION AND UNITED STATES RESIDENTS

If you are a resident of the European Union, you have the right under the GDPR to request access, rectification, erasure, restriction, portability, and to object to processing or withdrawal consent. We process your Personal Data primarily to perform our contractual obligations to you (for example, when you subscribe to the Services), and where necessary for legal compliance or legitimate business interests. If you are a resident of the United States, your rights may vary depending on applicable law. At a minimum, you may opt out of marketing communications at any time by using the unsubscribe option provided in our emails, Telegram messages, or by contacting us via our official support channel at support@domkralovykh.com. Please note that even if you opt out of marketing communications, we may continue to send service-related or transactional messages via Telegram, Zoom, or email that are necessary for the operation of the Services.

12. CHANGES TO THIS PRIVACY POLICY

We reserve the right to amend this Privacy Policy at any time to reflect changes in legal, regulatory, or operational requirements, or to update our data practices. Any modifications will take effect upon publication of the updated version on the Platform (including the Telegram bot, Telegram channels, or any website used by the Company), unless otherwise specified. The "Last Updated" date at the top of this document will indicate the date of the latest revision. We may, but are not obliged to, notify you of material changes via Telegram, email, or other official communication channels. By continuing to use the Platform or participate in the Services after such updates, you accept the revised Policy. If you do not agree, you must stop using the Services. If you have any questions, concerns, or requests regarding this Privacy Policy, you may contact us via our official support channel.

Trading Education OÜ
Registration code: 17156734
Address: Harju maakond, Tallinn, Lasnamäe linnaosa, Tähesaju tee 21-114, 13917, Estonia

Email: support@thomaskralow.com