1. Processed data
As part of the newsletter or waitlist registration, first name, last name, email address, trading experience, traded markets and any other data voluntarily entered by the user in the form may be processed.
Technical data regarding the management of the mailing list may also be processed, such as the date and time of subscription, proof of consent, expressed preferences, withdrawals, unsubscribes and data necessary to prevent unwanted mailings or disputes.

2. Purpose of processing
Sending newsletters, promotional communications, updates on products, services, offers, new releases and editorial content from NoEmoji Trader.
Light segmentation and organisation of lists based on user preferences or provided information, solely for the purpose of making communications more relevant.
Management of consent proof, withdrawal requests, unsubscribes and mailing list security.

Legal basis
For sending newsletters and promotional communications, the legal basis is the data subject's free, specific, informed and unambiguous consent pursuant to Article 6(1)(a) of the GDPR and the equivalent provision of the UK GDPR.
For the management of proof of consent, withdrawals, technical blacklists and defence in the event of disputes, the legal basis is the legitimate interest of the data controller pursuant to Art. 6, para. 1, letter f) of the GDPR.
Providing the data is optional. Without consent, the user will not receive the newsletter or promotional communications, but will suffer no other consequences.

4. Method of processing
Processing is carried out mainly using electronic tools and via the e-mail marketing platform Brevo, used by the data controller for the management of the newsletter and mailing list, in the capacity of data processor where applicable.
No automated decision-making producing legal effects or similarly significant effects pursuant to Art. 22 GDPR is envisaged. Any internal list segmentation activities do not produce legal effects on the data subject.

5. Recipients and transfers
Data may be processed by technical suppliers, hosting providers, authorised consultants and email marketing platforms strictly necessary for the management of the newsletter.
If the data is processed in the United Kingdom or transferred to other third countries via the suppliers used, the data controller shall adopt the transfer mechanisms provided for by applicable law, such as adequacy decisions or standard contractual clauses.

6. Storage
Data is retained until consent is withdrawn or upon unsubscription. After unsubscription, data is removed or anonymised within a reasonable timeframe, as a rule within 30 days, barring legal obligations or the need to document the proper management of consent.

7. Data subject rights
The data subject may exercise their rights of access, rectification, erasure, restriction, objection, portability and withdrawal of consent at any time by writing to privacy@noemojitrader.com.
Without prejudice to the right to lodge a complaint with the Garante per la protezione dei dati personali or, where applicable, the Information Commissioner’s Office.