Privacy Policy

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from https://www.tragoa.com. Protecting your private information is our priority.

This Statement of Privacy applies to https://tragoa.com and Tragoa Trading Company and governs data collection and usage. For the purposes of this Privacy Policy, unless otherwise noted, all references to Tragoa Trading Company include https://tragoa.com and TRAGOA. By using the TRAGOA website, you consent to the data practices described in this statement as well as the Terms of Service.

Collection of your Personal Information

In order to better provide you with products and services offered on our Site, TRAGOA may collect personally identifiable information, such as, but not limited to, your:

  • First and Last Name
  • Mailing Address
  • E-mail Address
  • Phone Number
  • ID Documents (and their information)
  • Business Documents (and their information)

If you purchase TRAGOA's products and services, we collect billing and credit card information. This information is used to complete the purchase transaction.

TRAGOA may also collect anonymous demographic information, which is not unique to you, such as, but not limited to, your:

  • Age
  • Gender

Please keep in mind that if you directly disclose personally identifiable information or personally sensitive data on TRAGOA this information may be collected and used by others. The avenues through which this may occur can be, but are not limited to: (a) public message boards; (b) member-to-member chats; (c) profile information; (d) product postings.

We do not collect any personal information about you unless you voluntarily provide it to us. However, you may be required to provide certain personal information to us when you elect to use certain products or services available on the Site. These may include, but are not limited to: (a) registering for an account on our Site; (b) using our verification services; (c) sending us an email message; (d) submitting your credit card or other payment information when ordering and purchasing products and services on our Site; (e) signing up for special offers from selected third parties. To wit, we will use your information for, but not limited to, communicating with you in relation to services and/or products you have requested from us. We also may gather additional personal or non-personal information in the future.

Use of your Personal Information

TRAGOA collects and uses your personal information to operate its website(s) and deliver the services you have requested and consented to through use of our Site.

TRAGOA may also use your personally identifiable information to inform you of other products or services available from TRAGOA and its affiliates.

Sharing Information with Third Parties

TRAGOA does not sell, rent or lease its customer lists to third parties.

TRAGOA may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, your unique personally identifiable information (email, name) may be transferred to the third party. TRAGOA may share data with trusted partners to, but not limited to, help perform statistical analysis, provide verification services, send you email or postal mail or otherwise communicate with you, provide customer support, or process payments. All such third parties are prohibited from using your personal information except to provide these services to TRAGOA, and they are required to maintain the confidentiality of your information.

TRAGOA may disclose your personal information, without notice, if required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the edicts of the law or comply with legal process served on TRAGOA or the Site; (b) protect and defend the rights or property of TRAGOA; and/or (c) act under exigent circumstances to protect the personal safety of users of TRAGOA, or the public.

Third parties we share with are:

  • Google. We use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here. You can also opt-out of Google Analytics here. If using your Google account to sign in we authorize your account using their services and the information you provide. The only information we ask for is your email, profile (first & last names), and id. We store none of this information from Google beyond the registration details and the authorization page.
  • Facebook. We use Facebook Analytics only if authorized to do so through your use of Facebook oAuth. To read more about how Facebook uses your Personal Information, visit here. If using your Facebook account to sign in we authorize your account using their services and the information you provide. The only information we ask for is your email, location (current city in your Facebook profile), and default profile info (id, first/middle/last names, name, name format, profile picture url, short name). We store none of this information from Facebook beyond the registration details and the authorization page.
  • Sum and Substance Ltd (SumSub). We use Sum and Substance Ltd only if authorized to do so by opting into and agreeing to the terms of the verification service offered on the Site. Their services are used to process data you submit in order to verify your identity and/or business. Once submitted, SumSub are the “processors” and TRAGOA are the “controllers”. For more information about SumSub visit here. By using this service you will need to consent to personal data processing by SumSub. This consent form can be found here. For more information about our optional verification services, and the terms of usage, visit here and here.
  • Tawk. We use Tawk to provide our customer support chat. Data is only shared if submitted by the user when initiating a chat, and includes the email address as well as the automatically collected data detailed below. For more information about Tawk visit here.

Opt-Out of Disclosure of Personal Information to Third Parties

In connection with any personal information we may disclose to a third party for a business purpose, you have the right to know:

  • The categories of personal information that we disclosed about you for a business purpose.

You have the right under the California Consumer Privacy Act of 2018 (CCPA) and other privacy and data protection laws, as applicable, to opt-out of the disclosure of your personal information. If you exercise your right to opt-out of the disclosure of your personal information, we will refrain from disclosing your personal information, unless you subsequently provide express authorization for the disclosure of your personal information. To opt-out of the disclosure of your personal information, contact us at privacy@tragoa.com.

Tracking User Behavior

TRAGOA may keep track of the websites and pages our users visit within TRAGOA, in order to determine what TRAGOA services are the most popular. This data is used to deliver customized content and advertising within TRAGOA to customers whose behavior indicates that they are interested in a particular subject area.

Automatically Collected Information

Information about your computer hardware and software may be automatically collected by TRAGOA. This information can include, but are not limited to: your IP address, browser type, domain names, location, access times, and referring website addresses. This information is used, in part, for the operation of the service, to maintain quality of the service, optimize our services, personalize our services, advertising and search engine optimization, security, and to provide general statistics regarding use of the TRAGOA website.

We collect this information using the following technologies:

  • "Cookies" are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit here.
  • "Log files" track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
  • "Web beacons", "tags", and "pixels" are electronic files used to record information about how you browse the Site.
  • "LocalStorage" is an in-browser storage area for data.
  • "Facebook Analytics" (only if user authorizes through Facebook oAuth). For more information on Facebook Analytics, visit here.
  • "Google Analytics". For more information on Google Analytics, visit here.
  • "Tawk.to". For more information on Tawk.to, visit here.
  • Microsoft Azure. For more information on Microsoft Azure, visit here

Behavioral Advertising

As described above, we may now, or in the future, use your Personal Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. For more information about how targeted advertising works, you can visit the Network Advertising Initiative’s (“NAI”) educational page here.

The potential targeted advertising platforms used are listed below, and you can opt out of targeted advertising by:

Additionally, you can opt out of some of these services by visiting the Digital Advertising Alliance’s opt-out portal here.

Use of Cookies and Web Storage

The TRAGOA website may use "cookies", or other forms of web storage (i.e. local storage, session storage, indexedDB) to help you personalize your online experience. A cookie is a text file that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you, and can only be read by a web server in the domain that issued the cookie to you. For more information regarding the various forms of Web Storage please visit here

One of the primary purposes of cookies and web storage is to provide a convenience feature to save you time. The purpose of a cookie and web storage is to tell the Web server that you have returned to a specific page without the use of a database. For example, if you personalize TRAGOA pages, or register with TRAGOA site or services, a cookie and web storage helps TRAGOA to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on. When you return to the same TRAGOA website, the information you previously provided can be retrieved quickly, so you can easily use the TRAGOA features that you customized.

You have the ability to accept or decline cookies, and clear all web storage. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies and clear web storage if you prefer. In Google Chrome’s browser you can visit here to access this functionality. Note, if you choose to decline cookies, you may not be able to fully experience the interactive features of the TRAGOA services or websites you visit.

Do Not Track

Please note that we do not alter our Site’s data collection and use practices when we see a Do Not Track signal from your browser.

Links

This website contains links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that collects personally identifiable information. This topic is covered further in our Terms of Service.

Security of your Personal Information

TRAGOA secures your personal information from unauthorized access, use, or disclosure. TRAGOA uses the following, but not only the following, methods for this purpose:

  • SSL Protocol
  • Data Encryption
  • Authorization Policies
  • Authentication (including multi-factor authentication)

When personal information (such as a credit card number) is transmitted to other websites, it is protected through the use of encryption, such as the Secure Sockets Layer (SSL) protocol. When your personal information is at rest it is protected through, but not limited to, encryption, authorization policies, and authentication.

We strive to take appropriate security measures to protect against unauthorized access to or alteration of your personal information. Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your personal information, you acknowledge that: (a) there are security and privacy limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and privacy of any and all information and data exchanged between you and us through this Site cannot be guaranteed.

We will aim to notify you of any pertinent information regarding the security of your data within applicable laws and regulations. Further information about our liabilities and responsibilities can be found in our Terms of Service.

Right to Deletion

Subject to certain exceptions set out below, on receipt of a verifiable request from you, we will:

  • Delete your personal information from our records; and
  • Direct any service providers to delete your personal information from their records.

Please note that we may not be able to comply with requests to delete your personal information if it is necessary to:

  • Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by you, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between you and us;
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity;
  • Debug to identify and repair errors that impair existing intended functionality;
  • Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law;
  • Comply with the California Electronic Communications Privacy Act;
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the achievement of such research, provided we have obtained your informed consent;
  • Enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us;
  • Comply with an existing legal obligation; or
  • Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

Data Retention

When you submit data to our Site through, but not limited to, registering, verifying, placing an order, other methods listed in this policy, etc., we will maintain your information for our records, only as long as necessary, unless and until you ask us to delete this information.

European Residents

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above.

Additionally, please note that your information will be transferred outside of Europe, including to Canada and the United States, and other countries.

Children Under Thirteen

TRAGOA does not knowingly collect personally identifiable information from children under the age of thirteen. If you are under the age of thirteen, you are not permitted to use this website as detailed in our Terms of Service.

Disconnecting your TRAGOA Account from Third Party Websites

You will be able to connect your TRAGOA account to third party accounts. BY CONNECTING YOUR TRAGOA ACCOUNT TO YOUR THIRD PARTY ACCOUNT, YOU ACKNOWLEDGE AND AGREE THAT YOU ARE CONSENTING TO THE CONTINUOUS RELEASE OF INFORMATION ABOUT YOU TO OTHERS (IN ACCORDANCE WITH YOUR PRIVACY SETTINGS ON THOSE THIRD PARTY SITES). IF YOU DO NOT WANT INFORMATION ABOUT YOU, INCLUDING PERSONALLY IDENTIFYING INFORMATION, TO BE SHARED IN THIS MANNER, DO NOT USE THIS FEATURE. You may disconnect your account from a third party account at any time. Users may disconnect their accounts from third-party websites by removing TRAGOA's permissions on the third party's website.

The following may help in regards to removing our permissions on third party websites:

  • Directions for removing permissions with Facebook can be found here.
  • Directions for removing permissions with Google can be found here.

Opt-Out & Unsubscribe from Third Party Communications

We respect your privacy and give you an opportunity to opt-out of receiving announcements of certain information. Users may opt-out of receiving any or all communications from third-party partners of TRAGOA by contacting us at privacy@tragoa.com.

E-mail Communications

From time to time, TRAGOA may contact you via email for, but not limited to, the purpose of providing announcements, promotional offers, alerts, confirmations, account services, surveys, and/or other general communication. In order to improve our Services, we may receive a notification when you open an email from TRAGOA or click on a link therein.

If you would like to stop receiving marketing or promotional communications via email from TRAGOA, you may opt out of such communications by clicking on the UNSUBSCRIBE link at the bottom of the email.

External Data Storage Sites

We may store your data on servers provided by third party hosting vendors with whom we have contracted.

Changes to this Statement

TRAGOA reserves the right to change this Privacy Policy from time to time. We will notify you about significant changes in the way we treat personal information by one or more of the following (a) sending a notice to the primary email address specified in your account; (b) placing a prominent notice on our Site; (c) updating any privacy information on this page. Your continued use of the Site and/or Services available through this Site after such modifications will constitute your: (a) acknowledgment of the modified Privacy Policy; and (b) agreement to abide and be bound by that Policy.

Contact Information

TRAGOA welcomes your questions or comments regarding this Statement of Privacy. If you believe that TRAGOA has not adhered to this Statement, please contact TRAGOA at:

Email Address:
privacy@tragoa.com

Telephone number:
+1 (202) 810-9696

Effective as of December 01, 2020