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DD-FX PRIVACY POLICY

Date: 19 January 2026
Version: 2.0

1) General

  1. DD-FX (“we”, “us”, “DD-FX”) respects users’ privacy and recognises that you expect your data to be handled securely, privately, and in compliance with applicable law. This Privacy Policy (“Policy”) explains what data we collect, why we collect it, the legal bases we rely on, who we share it with, how long we keep it, and your rights.

2) Data Controller and Scope

  1. 1.
    The data controller is DD-FX (the “Controller”).
  2. 2.
    This Policy applies to data processed in connection with: the website/user panel, registration and login, plan subscriptions, access to educational materials, publications and the archive, communications (e.g., email/messaging platforms), and—where implemented—tools supporting execution and analytics/marketing.

3) Acceptance of this Policy and Consent

  1. 1.
    By using the Service, creating an Account, making a purchase, or providing information to us in any form, you confirm that you have read this Policy and accept the rules described in it.
  2. 2.
    If you do not accept this Policy, you should stop using the Service and—where applicable—uninstall any solutions provided by DD-FX.
  3. 3.
    Where the law requires separate consent (e.g., for marketing or certain cookies), we will request it explicitly (e.g., via a checkbox or consent banner). You may withdraw consent at any time.

4) What Data We Collect

  1. 1.
    We collect two main categories of data:
  2. 2.
    A) Non-Personal Information: Information that does not directly identify you without additional data, for example: approximate geolocation, web requests, browser type and language, operating system, URLs visited before/after visiting the Service, click counts, landing pages, page views and order, time spent on pages, session parameters, performance and error logs. Purpose: security, statistics, usage auditing, affiliate auditing/settlement, and improving the Service.
  3. 3.
    B) Cookies and Similar Technologies: Non-personal information and some technical data may be collected via cookies, pixels, tags, local storage, etc. Details (including how to manage/disable them) are provided in the Cookie Policy and the consent banner.
  4. 4.
    C) Personal Information: Information that can identify you, or may be sensitive in a privacy context, such as: name (if provided), email address, telephone number (if provided), account data (ID, username), IP address, billing details, communications data. Account registration: we may collect data required to provide the Service (e.g., email, password, account identifier). Important: please do not send special category data (e.g., health, political views).

5) Why We Collect Data (Purposes) and What Happens If You Don’t Provide It

  1. 1.
    We collect data to: create and operate Accounts, provide access to plans/materials, process payments, respond to enquiries, analyse and improve the Service, conduct marketing (with consent).
  2. 2.
    Providing mandatory data is necessary to deliver the Service. If you do not provide required data, we may be unable to fully provide the Service.

6) Legal Bases for Processing (GDPR/UK GDPR)

  1. Depending on the circumstances, we process personal data based on: performance of a contract, legal obligations, legitimate interests (security, analytics), and consent.

7) Who We Share Data With (Recipients)

  1. 1.
    We may disclose data to: our corporate group, IT/hosting providers, payment providers, auditors/advisers, marketing partners (with consent), potential buyers, and public authorities.
  2. 2.
    Data processing agreements: processing by our service providers is governed by agreements requiring confidentiality and security.
  3. 3.
    We do not sell personal data to third parties.

8) Exceptional Disclosures: Security, Abuse, Enforcement

  1. We may disclose data to: detect/prevent fraud, enforce our terms, and protect the rights or safety of DD-FX and others.

9) How We Use Information

  1. We use data to: deliver the Service, maintain stability, process payments, contact you, conduct marketing (where lawful), and personalise the Service.

10) Data Retention (How Long We Keep Data)

  1. 1.
    Account data: for the duration of account activity and statutory limitation periods.
  2. 2.
    Transaction data: for periods required by law.
  3. 3.
    Security logs: as long as justified by security needs.
  4. 4.
    Marketing data: until consent is withdrawn.

11) Your Rights

  1. You may have rights to: access, rectify, erase, restrict processing, data portability, object to processing, withdraw consent, and lodge a complaint.

12) Data Security and Confidentiality

  1. 1.
    We apply industry measures (encryption, access controls). However, we cannot guarantee absolute security over the internet.
  2. 2.
    You are responsible for your login credentials.

13) Profiling and Automated Decision-Making

  1. 1.
    We may use basic profiling for security and analytics/marketing (with consent).
  2. 2.
    We do not make decisions with legal effects solely by automated processing unless necessary for a contract or permitted by law.

14) Links to Other Websites and Third-Party Services

  1. The Policy does not cover third parties’ practices. You use third-party sites at your own risk.

15) Assignment (Business Transfers)

  1. In the event of a change of control or asset sale, we may transfer data to a third party.

16) Children’s Data

  1. We do not knowingly process data of persons under 18.

17) Policy Updates and “GDPR Changes”

  1. We may update this Policy; updates apply from the publication date.

18) Contact and Exercising Your Rights

  1. For privacy matters, contact us via the contact channel provided within the Service.

Additional Protective Clause

  1. Processing is necessary for digital services. DD-FX is not responsible for independent actions of third parties (payment processors, hosting) whose infrastructure is used.