Privacy Policy
We are committed to maintaining the accuracy, security and privacy of Personal Information in accordance with applicable legislation. Please review the following policy to learn about our privacy policies. By accessing this website you consent to the policies herein.
1. Who We Are
The owner and operator of this website is Expert Golden Egg Ltd. (Hereinafter referred to as We, or Us). Expert Golden Egg Ltd., operates as Vladimir Ribakov.
2. Personal Information
By providing us with your personal information, you consent to the collection, use and disclosure of that information as described in this Policy.
3. Types of Information
The types of personal information we may collect about you includes, but may not be limited to, your name, contact information, billing information, credit card information, account information, address, billing and delivery information, telephone number, email address, IP address, financial account information, information relevant to your business, your opinion, other information related to your business and services, other data collected that could directly or indirectly identify you, and other information as you may wish to input through this web site.
4. Use of Personal Information
We collect and use your personal information to operate this Web Site and deliver the services and information you have requested, as well as other purposes that may be indicated to you at the time you provide your personal information. Such use of your personal information may include, but is not limited to: For the purpose of facilitating payment; We use information regarding your location to provide a customized experience; We may use cookies to provide a customized experience; To facilitate communication between parties; To provide you access to the products and / or services you request; To communicate in general; To respond to comments and / or questions; To improve our service and / or products; To notify you of product / services that may be of interest to you; To request information from you; To provide other information to you; To collect fees; To tailor content, advertising & marketing to you; To publish articles that provide information to site users; Any testimonials and / or reviews we receive may be published, using your name; Testimonials and / or reviews of both positive and negative and or / unflattering nature.
5. How we use your personal data
In this Section we have set out:
- the general categories of personal data that we may process;
- in the case of personal data that we did not obtain directly from you, the source and specific categories of that data;
- the purposes for which we may process personal data;
- the legal bases of the processing.
a. We may process data about your use of our website and services (“usage data”). The usage data may include your IP address, geographical location, browser type and version, operating system, referral source, length of visit, page views and website navigation paths, as well as information about the timing, frequency and pattern of your service use. The source of the usage data is GetClicky, PushCrew , Aweber or Googly Analytics. This usage data may be processed for the purposes of analysing the use of the website and services. The legal basis for this processing is our legitimate interests, namely monitoring and improving our website and services.
b. We may process your account data (“account data”). The account data may include your name, phone number and email address. The source of the account data is you. The account data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
c. We may process your information included in your personal profile on our website (“profile data”). The profile data may include your name, address, telephone number, email address, profile pictures, gender and date of birth. The profile data may be processed for the purposes of enabling and monitoring your use of our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
d. We may process your personal data that are provided in the course of the use of our services (“service data”). The service data may include your name, address, telephone number, email address, profile pictures, gender and date of birth .The source of the service data is you. The service data may be processed for the purposes of operating our website, providing our services, ensuring the security of our website and services, maintaining back-ups of our databases and communicating with you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
e. We may process information that you post for publication on our website or through our services (“publication data”). The publication data may be processed for the purposes of enabling such publication and administering our website and services. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business.
f. We may process information contained in any enquiry you submit to us regarding goods and/or services (“enquiry data”). The enquiry data may be processed for the purposes of offering, marketing and selling relevant goods and/or services to you. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business. .
g. We may process information relating to our customer relationships, including customer contact information (“customer relationship data”). The customer relationship data may include your name, your contact details, and information contained in communications between us. The source of the customer relationship data is you. The customer relationship data may be processed for the purposes of managing our relationships with customers, communicating with customers, keeping records of those communications and promoting our products and services to customers. The legal basis for this processing is our legitimate interests, namely the proper management of our customer relationships.
h. We may process information relating to transactions, including purchases of goods and services, that you enter into with us and/or through our website (“transaction data”). The transaction data may include your name, your contact details and the transaction details. The transaction data may be processed for the purpose of supplying the purchased goods and services and keeping proper records of those transactions. The legal basis for this processing is the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract and our legitimate interests, namely the proper administration of our website and business.
i. We may process information that you provide to us for the purpose of subscribing to our email notifications and/or newsletters (“notification data”). The notification data may be processed for the purposes of sending you the relevant notifications and/or newsletters and/ or for marketing purposes. The legal basis for this processing is consent.
j. We may process information contained in or relating to any communication that you send to us (“correspondence data”). The correspondence data may include the communication content and metadata associated with the communication. Our website will generate the metadata associated with communications made using the website contact forms. The correspondence data may be processed for the purposes of communicating with you and record-keeping. The legal basis for this processing is our legitimate interests, namely the proper administration of our website and business and communications with users.
k. We may process any of your personal data identified in this policy where necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure. The legal basis for this processing is our legitimate interests, namely the protection and assertion of our legal rights, your legal rights and the legal rights of others.
l. We may process any of your personal data identified in this policy where necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice. The legal basis for this processing is our legitimate interests, namely the proper protection of our business against risks.
m. In addition to the specific purposes for which we may process your personal data set out in this Section, we may also process any of your personal data where such processing is necessary for compliance with a legal obligation to which we are subject, or in order to protect your interests or the interests of another person. We may share personal information in response to a request from a judicial authority. Such disclosure may be outside of any jurisdiction that you are present in. We may waive any defence available to us. We may share personal information in connection with a corporate transaction such as a merger, take over, etc. We may share aggregate and or anonymous information with 3rd parties for other purposes including but not limited to promotion, marketing, investment solicitations, etc.
n. Please do not supply any other person’s personal data to us, unless we prompt you to do so.
6. Providing your personal data to others
a. We may disclose your personal data to our insurers and/or professional advisers insofar as reasonably necessary for the purposes of obtaining or maintaining insurance coverage, managing risks, obtaining professional advice, or the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
b. We may disclose your personal data to our suppliers or subcontractors insofar as necessary for the proper administration of our website and business, and who may provide services on our behalf.
c. Financial transactions relating to our website and services are handled by our payment services providers – Paypal and CoinPayments. We will share transaction data with our payment services providers only to the extent necessary for the purposes of processing your payments, refunding such payments and dealing with complaints and queries relating to such payments and refunds. You can find information about the payment services providers’ privacy policies and practices at
https://www.paypal.com/ca/webapps/mpp/ua/privacy-full
https://www.coinpayments.net/help-privacy
d. We may disclose your enquiry data to one or more of those selected third party suppliers of goods and services identified on our website for the purpose of enabling them to contact you so that they can offer, market and sell to you relevant goods and/or services. Each such third party will act as a data controller in relation to the enquiry data that we supply to it; and upon contacting you, each such third party should supply to you a copy of its own privacy policy, which will govern that third party’s use of your personal data.
e. In addition to the specific disclosures of personal data set out in this Section, we may disclose your personal data where such disclosure is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person. We may also disclose your personal data where such disclosure is necessary for the establishment, exercise or defence of legal claims, whether in court proceedings or in an administrative or out-of-court procedure.
7. International transfers of your personal data
a. In this Section, we provide information about the circumstances in which your personal data may be transferred to countries outside the European Economic Area (EEA).
b. We and our other group companies have offices and facilities in Israel, Bulgaria and Canada . The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission
c. The hosting facilities for our website are situated in Ireland. The European Commission has made an “adequacy decision” with respect to the data protection laws of each of these countries. Transfers to each of these countries will be protected by appropriate safeguards, namely the use of standard data protection clauses adopted or approved by the European Commission.
d. You acknowledge that personal data that you submit for publication through our website or services may be available, via the internet, around the world. We cannot prevent the use or misuse of such personal data by others.
e. You acknowledge and agree that data held may be transferred from your current location to our offices and servers and authorized third parties referred to in this Privacy Policy located in Ireland, Bulgaria, Israel and Canada.
8. Retaining and deleting personal data
a. This Section sets out our data retention policies and procedure, which are designed to help ensure that we comply with our legal obligations in relation to the retention and deletion of personal data.
b. Personal data that we process for any purpose or purposes shall not be kept for longer than is necessary for that purpose or those purposes.
c. We will retain your personal data as follows:
- Name, email, phone number, your personal profile and statistics regarding opening our emails sent to your email address will be retained for a minimum period of 6 months following sign up or purchase date, and for a maximum period of 1 year if you are not opening emails, or will be retained without a maximum period as long as you are an active subscriber or client.
- Your IP address is monitored by our data analytics software as long as you keep visiting our websites.
- Your transaction data is retained for a minimal time of 3 years for a maximum period of 10 years.
d. Notwithstanding the other provisions of this Section 6, we may retain your personal data where such retention is necessary for compliance with a legal obligation to which we are subject, or in order to protect your vital interests or the vital interests of another natural person.
9. Modifications
a. We reserve the right to modify or supplement this Privacy Policy at any time, without prior notice, you agree to be bound by such modifications and or supplements.
b. We may update this policy from time to time by publishing a new version on our website.
c. You should check this page occasionally to ensure you are happy with any changes to this policy.
d. We may notify you of significant changes to this policy by email or through the private messaging system on our website.
10. Your rights
a. In this Section, we have summarised the rights that you have under data protection law. Some of the rights are complex, and not all of the details have been included in our summaries. Accordingly, you should read the relevant laws and guidance from the regulatory authorities for a full explanation of these rights.
b. Your principal rights under data protection law are:
- the right to access;
- the right to rectification;
- the right to erasure;
- the right to restrict processing;
- the right to object to processing;
- the right to data portability;
- the right to complain to a supervisory authority; and
- the right to withdraw consent.
c. You have the right to confirmation as to whether or not we process your personal data and, where we do, access to the personal data, together with certain additional information. That additional information includes details of the purposes of the processing, the categories of personal data concerned and the recipients of the personal data. Provided the rights and freedoms of others are not affected, we will supply to you a copy of your personal data. The first copy will be provided free of charge, but additional copies may be subject to a reasonable fee.
You can access your personal data by sending us an email to support@hometraderclub.com and we will send it within 1 to 5 business days.
d. You have the right to have any inaccurate personal data about you rectified and, taking into account the purposes of the processing, to have any incomplete personal data about you completed.
e. In some circumstances you have the right to the erasure of your personal data without undue delay. Those circumstances include: the personal data are no longer necessary in relation to the purposes for which they were collected or otherwise processed; you withdraw consent to consent-based processing; you object to the processing under certain rules of applicable data protection law; the processing is for direct marketing purposes; and the personal data have been unlawfully processed. However, there are exclusions of the right to erasure. The general exclusions include where processing is necessary: for exercising the right of freedom of expression and information; for compliance with a legal obligation; or for the establishment, exercise or defence of legal claims.
f. In some circumstances you have the right to restrict the processing of your personal data. Those circumstances are: you contest the accuracy of the personal data; processing is unlawful but you oppose erasure; we no longer need the personal data for the purposes of our processing, but you require personal data for the establishment, exercise or defence of legal claims; and you have objected to processing, pending the verification of that objection. Where processing has been restricted on this basis, we may continue to store your personal data. However, we will only otherwise process it: with your consent; for the establishment, exercise or defence of legal claims; for the protection of the rights of another natural or legal person; or for reasons of important public interest.
g. You have the right to object to our processing of your personal data on grounds relating to your particular situation, but only to the extent that the legal basis for the processing is that the processing is necessary for: the performance of a task carried out in the public interest or in the exercise of any official authority vested in us; or the purposes of the legitimate interests pursued by us or by a third party. If you make such an objection, we will cease to process the personal information unless we can demonstrate compelling legitimate grounds for the processing which override your interests, rights and freedoms, or the processing is for the establishment, exercise or defence of legal claims.
h. You have the right to object to our processing of your personal data for direct marketing purposes (including profiling for direct marketing purposes). If you make such an objection, we will cease to process your personal data for this purpose.
i. You have the right to object to our processing of your personal data for scientific or historical research purposes or statistical purposes on grounds relating to your particular situation, unless the processing is necessary for the performance of a task carried out for reasons of public interest.
j. To the extent that the legal basis for our processing of your personal data is:
- consent;
- that the processing is necessary for the performance of a contract to which you are party or in order to take steps at your request prior to entering into a contract,
and such processing is carried out by automated means, you have the right to receive your personal data from us in a structured, commonly used and machine-readable format. However, this right does not apply where it would adversely affect the rights and freedoms of others.
k. If you consider that our processing of your personal information infringes data protection laws, you have a legal right to lodge a complaint with a supervisory authority responsible for data protection. You may do so in the EU member state of your habitual residence, your place of work or the place of the alleged infringement.
l. To the extent that the legal basis for our processing of your personal information is consent, you have the right to withdraw that consent at any time. Withdrawal will not affect the lawfulness of processing before the withdrawal.
m. You may exercise any of your rights in relation to your personal data by written notice to us via email to support@hometraderclub.com.
11. About cookies
a. A cookie is a file containing an identifier (a string of letters and numbers) that is sent by a web server to a web browser and is stored by the browser. The identifier is then sent back to the server each time the browser requests a page from the server.
b. Cookies may be either “persistent” cookies or “session” cookies: a persistent cookie will be stored by a web browser and will remain valid until its set expiry date, unless deleted by the user before the expiry date; a session cookie, on the other hand, will expire at the end of the user session, when the web browser is closed.
c. Cookies do not typically contain any information that personally identifies a user, but personal information that we store about you may be linked to the information stored in and obtained from cookies.
12. Cookies that we use
a. We use cookies for the following purposes:
- authentication – we use cookies to identify you when you visit our website and as you navigate our website (cookies used for this purpose are: Session, Persistent)
- status – we use cookies to help us to determine if you are logged into our website , cookies used for this purpose are: Session, Persistent
- personalisation – we use cookies to store information about your preferences and to personalise the website for you, cookies used for this purpose are: Session, Persistent
- security – we use cookies as an element of the security measures used to protect user accounts, including preventing fraudulent use of login credentials, and to protect our website and services generally, (cookies used for this purpose are: Session, Persistent
- advertising – we use cookies [to help us to display advertisements that will be relevant to you, cookies used for this purpose are: Session, Persistent;
- analysis – we use cookies to help us to analyse the use and performance of our website and services cookies used for this purpose are: Session, Persistent
- cookie consent – we use cookies to store your preferences in relation to the use of cookies more generally, cookies used for this purpose are: Session, Persistent
13. Cookies used by our service providers
a. Our service providers use cookies and those cookies may be stored on your computer when you visit our website.
b. We use GetClicky and Google Analytics to analyse the use of our website. GetClicky and Google Analytics gathers information about website use by means of cookies. The information gathered relating to our website is used to create reports about the use of our website. Google’s privacy policy is available at: https://www.google.com/policies/privacy/. GetClicky’s privacy policy is available at: https://clicky.com/terms/privacy
c. We use PushCrew to send push notifications. This service uses cookies for sending notifications. You can view the privacy policy of this service provider at https://pushcrew.com/privacy-policy/
14. Managing cookies
a. Most browsers allow you to refuse to accept cookies and to delete cookies. The methods for doing so vary from browser to browser, and from version to version. You can however obtain up-to-date information about blocking and deleting cookies via these links:
b. Blocking all cookies will have a negative impact upon the usability of many websites.
c. If you block cookies, you will not be able to use all the features on our website.
15. Links to Other Sites
This website may contain links to other websites. We are not responsible for the privacy practices or the content of such websites.
16. Protection of Personal Information
The security of your personal information is important to us. We attempt to protect your personal information with safeguards and security measures. Such measures include the use of the Secure Socket Layer protocol.
17. Information Security
We implement security measures to help protect against unauthorized access to or unauthorized alteration, disclosure, or destruction of data. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, we cannot guarantee or warrant the security of any data you transmit to us, or which we hold.
18. "Opting-out" or Withdrawing Your Consent
If you decide that you do not want to receive marketing offers for products and services, you may withdraw or refuse your consent at any time by contacting us (refer to the contact information at the bottom of this page). Your request will be processed but may not be in time to remove you from communications already in progress. Please note that even if you have opted out of receiving marketing communications, we may still contact you for purposes of administering your account.
19. Request for Information
Once a calendar year, you are entitled to request and obtain from us, information about the personal information shared, if any, with other businesses for marketing uses. If applicable, this information would include the categories of personal information and the names and addresses of those businesses with which we shared such personal information for the immediately prior calendar year (e.g., requests made in 2019 will receive information about 2018). To obtain this information please send your request to (please include your full name and address) to the contact information below.
20. The Consequences of Withdrawing or Refusing Consent
If you refuse or withdraw your consent for such disclosure we may not be able to provide you or continue to provide you with certain services or information.
21. Questions
Your privacy is important to us. If you have any questions please write to us. We attempt to respond in a reasonable time to questions and concerns about privacy policy and procedures. In most cases, an issue can be resolved simply by telling us about it and discussing any issues, please contact us at your convenience using the contact information below
22. Our details
a. This website is owned and operated by Expert Golden Egg LTD.
b. We are registered under registration number 515195501 and our correspondence address is Kemp House, 152 – 160 City Road, London EC1V 2NX, UK.
c. Our principal place of business is at Kemp House, 152 – 160 City Road, London EC1V 2NX, UK.
d. You can contact us:
- By post to Kemp House, 152 – 160 City Road, London EC1V 2NX, UK
- By Email to support@hometraderclub.com or support@TradersAcademyClub.com
- By telephone, on +44 123 4480569
- By Skype, at TopForex.Support
23. Data protection officer
a. Our data protection officer’s contact details are:
Gal Friedman
- By email: partners@vladimirribakov.com
- By phone, on +44 123 4480569
- By Skype, at TopForex.Support
- By post: to Kemp House, 152 – 160 City Road, London EC1V 2NX, UK