Privacy Policy

The Prop Association (TPA) is committed to protecting your privacy.  This Privacy Policy explains we collect, use, disclose, and safeguard your information when you visit our website, use our platform, or engage with any of our services.  This policy also explains your rights regarding your personal data and how you can exercise those rights.

We use your personal data to provide and improve our service. By using our service, you agree to the collection and use of information in accordance with this Privacy Policy.

1. INTERPRETATION AND DEFINITIONS

1.1 Interpretation: Capitalized words have specific meanings defined in the following conditions. These definitions apply whether the words appear in singular or plural.

1.2 Definitions For the purposes of this Privacy Policy:

• Account: A unique account created for you to access our service or parts of it.
• Affiliate: An entity that controls, is controlled by, or is under common control with a party. “Control” means ownership of 50% or more of the shares, equity interest, or other voting securities.
• Company: Refers to The Prop Association, located in the British Virgin Islands.
• Cookies: Small files placed on your device by a website, containing details of your browsing history on that website.
• Country: Refers to the British Virgin Islands.
• Device: Any device that can access the service, such as a computer, cellphone, or tablet.
• Personal Data: Any information relating to an identified or identifiable individual.
• Service: Refers to the website.
• Service Provider: Any person or entity who processes data on behalf of the Company.
• Third-party Social Media Service: Any website or social network through which a user can log in or create an account to use the service.
• Usage Data: Data collected automatically, generated either by the use of the service or from the service infrastructure itself.
• Website: The Prop Association, accessible from https://www.propassociation.com/
• You: The individual accessing or using the service, or the company or other legal entity on behalf of which such individual is accessing or using the service.

   

2. COLLECTING AND USING YOUR PERSONAL DATA

2.1 Types of Data Collected

(a) Personal Data

While using our service, we may ask you to provide us with certain personally identifiable information, including but not limited to:

• Contact information (e.g., name, email address)
• Identification and verification information (e.g., government-issued ID)
• Trading account data submitted in the course of reviews or use of our dispute resolution services
• Platform usage data (e.g., IP address, device data, browser type, access times)
• User-submitted content (e.g., reviews, complaints, audio/video content)
• Technical data (e.g., cookies and analytics identifiers)

(b) Usage Data
Usage Data is collected automatically when using the service. It may include information such as your device’s Internet Protocol address, browser type and version, pages of our service that you visit, time and date of your visit, time spent on those pages, unique device identifiers, and other diagnostic data.

(c)  If you choose to register or log in to our services using a Third-Party Social Media Service, we may have access to certain information from your account, such as your name, email address, and other account details.

2.2 Use of Your Personal Data
The Company may use Personal Data for the following purposes:

• To provide and maintain our service
• To verify identity and establish Trader User accounts
• To manage your account
• To process and display reviews and complaints submitted by users

• To fulfill any contracts you have with us through the service
• To contact you regarding updates or communications about our service
• To provide you with news, special offers, and general information about our services
• To manage your requests to us
• To facilitate dispute resolution between users and Member Firms
• To maintain the integrity and transparency of the platform
• To comply with our legal obligations and enforce our Terms of Use
• For data analysis, identifying usage trends, and improving our service
• To improve the website functionality and user experience

   

2.3 Retention of Your Personal Data
We will retain your Personal Data only for as long as necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations, resolve disputes, and enforce our legal agreements and policies.

2.4 Transfer of Your Personal Data
Your information may be transferred to—and processed in—computers located outside your state, province, country, or governmental jurisdiction, where data protection laws may differ from those in your jurisdiction.

We ensure that when your Personal Data is transferred outside of the British Virgin Islands or your country, adequate safeguards are in place to protect it in accordance with applicable data protection laws, including but not limited to:

1. GDPR (General Data Protection Regulation): For users in the European Union, we implement Standard Contractual Clauses (SCCs) approved by the European Commission to safeguard the transfer of data outside the EU. These clauses ensure that your Personal Data receives the same level of protection it would in the EU.

    

2. Other Adequate Measures: Where applicable, we may also rely on binding corporate rules, certifications, or additional contractual agreements with third parties to ensure that any transfer of your data complies with privacy regulations such as the CCPA (California Consumer Privacy Act) and others.

By using our Service and providing your information, you consent to the transfer of your Personal Data to other jurisdictions, subject to the protections outlined in this Privacy Policy.

2.5 Delete Your Personal Data
You have the right to delete or request that we assist in deleting the Personal Data that we have collected about you. Our service may give you the ability to delete certain information about you from within the service.

2.6 Consent for Data Collection 

We are committed to complying with global data privacy laws, including the General Data Protection Regulation (GDPR) and the California Consumer Privacy Act (CCPA), where applicable. By using our Service, you provide your consent for the collection, use, and processing of your Personal Data as outlined in this Privacy Policy.

Explicit Consent:

• Obtaining Consent: We will obtain your explicit consent before collecting, using, or sharing your Personal Data, where required by applicable law. You will be presented with clear and accessible options to agree to or decline the collection and processing of your Personal Data.
• Purpose of Data Collection: We will clearly explain the purpose of data collection at the point of consent, including how the data will be used and processed, and your ability to withdraw consent at any time.
• Withdrawing Consent: You have the right to withdraw your consent at any time by contacting us at privacy@propassociation.com. Upon receiving your request to withdraw consent, we will stop processing your Personal Data unless otherwise required by law.

Cookie Consent:

We use cookies and similar tracking technologies to provide and improve our Service. When you first access our website, you will be prompted with a cookie consent banner that gives you the option to accept or refuse cookies. You can manage your cookie preferences at any time by adjusting your browser settings or using the cookie settings tool provided on our website. Refusing cookies may affect the functionality of certain parts of our Service.

Consent for Minors:

If you are under the age of 13, or the age required by applicable law, we require parental or guardian consent before collecting your Personal Data. We do not knowingly collect Personal Data from individuals under the required age without verified consent. If we become aware of such data collection, we will take steps to delete the information.

2.7 Your Data Protection Rights

We are committed to ensuring that you are fully aware of your data protection rights under the General Data Protection Regulation (GDPR) and other applicable data protection laws. You have the following rights regarding your Personal Data:

(a) Right to Access: You have the right to request copies of the Personal Data we hold about you. We may charge a small fee for this service if permitted by applicable law. You can request this information by contacting us at privacy@propassociation.com.

(b) Right to Rectification: You have the right to request that we correct any information you believe is inaccurate or incomplete. If you believe any of the Personal Data we hold about you is incorrect, you can request a correction by contacting us at privacy@propassociation.com.

(c) Right to Erasure (Right to be Forgotten):  You have the right to request that we erase your Personal Data, under certain conditions. Upon receiving such a request, we will promptly take steps to delete your information unless we are legally required to retain it. You can exercise this right by contacting us at privacy@propassociation.com.

(d) Right to Restrict Processing: You have the right to request that we restrict the processing of your Personal Data, under certain conditions. This means that while we may still store your data, we will not process it further without your consent, unless required by law.

(e) Right to Data Portability:  You have the right to request that we transfer the data we have collected about you to another organization, or directly to you, under certain conditions. We will provide this data in a commonly used and machine-readable format. To request data portability, please contact us at privacy@propassociation.com.

(f) Right to Object Processing: You have the right to object to our processing of your Personal Data for direct marketing purposes or under other legitimate interest grounds, where applicable. If you object, we will stop processing your data unless we can demonstrate compelling legitimate grounds for the processing.

(g) Right to Withdraw Consent:  If we are processing your Personal Data based on your consent, you have the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of any processing conducted prior to the withdrawal. To withdraw consent, please contact us at privacy@propassociation.com.

(h) Right to Complaint: If you believe we are not complying with data protection laws, you have the right to lodge a complaint with a supervisory authority. For users in the European Union, this would be your local data protection authority.

2.8 Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience on our website, analyze traffic, and provide personalized content. Cookies are small text files stored on your device when you visit our website. By using our Service, you consent to the use of cookies as described in this Privacy Policy.

(a) Types of Cookies We Use: 

Essential Cookies: These cookies are necessary for the website to function properly. They enable core functionalities such as account login, security, and page navigation.

* Analytics Cookies: These cookies help us understand how visitors interact with our website by collecting and reporting information anonymously. This data allows us to improve website functionality and user experience.

* Functionality Cookies: These cookies remember your preferences and selections (e.g., language settings, login details) to provide a more personalized experience.

* Advertising Cookies: These cookies track your browsing activity to deliver personalized advertisements relevant to your interests. They may also be used to limit the number of times you see an ad and measure the effectiveness of advertising campaigns.

(b) Cookie Consent: When you first access our website, a cookie consent banner will appear that provides you with the option to:

* Accept All Cookies: This enables the use of all cookies, including those for analytics and advertising.

* Customize Cookie Preferences: You can select which types of cookies you would like to allow or disable.

* Reject Non-Essential Cookies: You may choose to allow only essential cookies, which are required for the website’s core functionality.

You can manage your cookie preferences through the banner or at any time by visiting the Cookie Preferences section of our website. Please note that disabling cookies may affect certain features of our Service.

(c) Managing Cookies: Most browsers provide options to manage or delete cookies. You can:

* View Cookies: See which cookies are stored on your device.

* Delete Cookies: Remove cookies from your browser.

* Block Cookies: Prevent new cookies from being placed on your device.

* Clear Cookies: Erase cookies stored on your device, including those that save your preferences.

Keep in mind that blocking or clearing cookies may impact the functionality of certain parts of our website.

(d) Other Tracking Technologies:

In addition to cookies, we may use similar tracking technologies such as web beacons, pixel tags, or device fingerprinting to collect information about your interactions with our website and improve our Service.

3. DISCLOSURE OF YOUR PERSONAL DATA

We may disclose your Personal Data under the following circumstances, ensuring that third parties comply with applicable privacy laws and maintain the confidentiality and security of your data:

1. With Service Providers: We share your Personal Data with trusted third-party service providers who assist us in providing, maintaining, and improving our services. These service providers may process data on our behalf for purposes such as:

(i) Data Hosting and Storage: Hosting your Personal Data on secure servers.

* Payment Processing: Facilitating payments and managing billing processes.

* Analytics and Performance: Analyzing website usage and performance to help us improve our services.

* Marketing and Communications: Managing email marketing campaigns, customer engagement, and communications.

All third-party service providers are contractually required to handle your Personal Data in accordance with this Privacy Policy and are prohibited from using it for any purpose other than those specified by us.

1. With Affiliates and Business Partners: We may share your Personal Data with our affiliates or trusted business partners for purposes that include:

* Joint Promotions and Offers: To offer joint promotions or services that may be of interest to you.

* Cross-Platform Integration: To provide integrated services or enhance your experience across different platforms affiliated with The Prop Association.

These affiliates and partners are subject to similar data protection obligations and will only process your data for the agreed purposes.

1. For Business Transfers:  In the event of a merger, acquisition, or sale of assets, your Personal Data may be transferred as part of the business transaction. We will ensure that any entity acquiring your information adheres to this Privacy Policy, and we will notify you if such a transfer occurs.

    

2. To Comply with Legal Obligations: We may disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g., a court or government agency). This may include complying with legal processes, enforcing our agreements, and protecting the rights, privacy, safety, or property of The Prop Association and its users.

    

3. With Your Consent: We may share your Personal Data with third parties when you have provided explicit consent for us to do so. This could include situations where you opt-in to share data for specific offers or services.

4. SECURITY OF YOUR PERSONAL DATA

4.1 Security Measures

We are committed to ensuring the security of your Personal Data. We implement a variety of technical, administrative, and physical safeguards designed to protect your information from unauthorized access, disclosure, alteration, or destruction. These measures include, but are not limited to:

1. Encryption: We use industry-standard encryption protocols, such as Secure Socket Layer (SSL) and Transport Layer Security (TLS), to protect Personal Data transmitted over the Internet.

    

2. Access Controls: Access to Personal Data is restricted to authorized personnel only, and access is granted based on a need-to-know basis. Multi-factor authentication (MFA) is implemented for sensitive systems to further secure access.

    

3. Data Anonymization: In certain cases, Personal Data is anonymized or pseudonymized to enhance privacy protections.

    

4. Regular Security Audits: We conduct regular audits and assessments of our security practices to ensure their effectiveness. This includes periodic penetration testing and vulnerability assessments.

    

5. Data Backups: We maintain regular backups of data to ensure integrity and availability in case of data loss or disaster recovery.

However, please be aware that no method of transmission over the Internet or method of electronic storage is 100% secure. While we strive to use commercially reasonable means to protect your Personal Data, we cannot guarantee its absolute security. You are responsible for ensuring the security of any passwords, account registration credentials, or other forms of authentication used to access our services.

If you become aware of any breach of security or unauthorized access to your account, please notify us immediately at privacy@propassociation.com, so we can take the appropriate steps to secure your account and Personal Data.

4.2 Data Breach Notification

In the event of a data breach that may compromise the security of your Personal Data, we will take the following steps:

1. User Notification: We will notify you promptly, within the timeframes required by applicable laws, if we determine that your Personal Data may have been affected by the breach. Notifications may include:

    

   • A description of the nature of the breach.
   • The type of Personal Data affected.
   • Steps we have taken to mitigate the breach.
   • Recommended actions you can take to protect yourself.

Notifications will be provided via email or through your account dashboard, depending on the information available to us.

1. Regulatory Notification: We will notify relevant data protection authorities, as required by applicable laws (e.g., GDPR mandates notification within 72 hours of becoming aware of the breach).

    

2. Investigation and Mitigation: Upon identifying a data breach, we will immediately initiate an internal investigation to determine its scope and take necessary measures to prevent further unauthorized access. This includes identifying and addressing any vulnerabilities that may have caused or contributed to the breach.

If you suspect a breach or unauthorized access to your account, please contact us immediately at mailto:privacy@propassociation.com, so we can take appropriate steps to secure your account and Personal Data.

5. AUTOMATED DECISION-MAKING

TPA does not use automated decision-making or profiling that produces legal or similarly significant effects. If this changes, we will update this Privacy Policy and offer opt-out rights where required.

6. AUDIO/VIDEO SUBMISSIONS

If you submit videos, voice recordings, screen captures, or other audiovisual materials as part of a complaint, review, or testimonial, you consent to our processing, publication, and retention of such content in accordance with this policy.

5. CHILDREN’S PRIVACY

Our service does not address anyone under the age of 13. We do not knowingly collect personally identifiable information from anyone under the age of 13. If we become aware that we have collected Personal Data from anyone under the age of 13 without verification of parental consent, we will take steps to remove that information from our servers.

6. LINKS TO OTHER WEBSITES

Our service may contain links to other websites that are not operated by us. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

7. CHANGES TO THIS PRIVACY POLICY

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page and updating the “Last updated” date.

8. CONTACT US

If you have any questions about this Privacy Policy, you can contact us:

• By email: privacy@propassociation.com
• By visiting this page on our website: https://www.propassociation.com/contact