Tradewind East Inc., (Delaware (US)), registered address: 33 Arch Street, 17th Floor, Boston, MA 02110, USA (“Tradewind East Inc”) provides services designed for real estate agents that support sales and marketing processes and allow to communicate with clientele, create and send messages, such as emails (hereinafter referred to as: “the Services”), available through mobile application (designed for use on Apple’s iOS-powered iPhone devices and on Android devices) named: Tradewind Messenger, developed, operated, and maintained by Tradewind East Inc (hereinafter referred to as: “Tradewind Messenger”), along with ancillary tools and services provided by Tradewind East Inc in connection therewith.

The Services are provided under this Privacy Policy.

This Privacy Policy is provided to explain Tradewind East Inc’s data practices, policies and procedures regarding collection, use, processing, disclosure and sharing of the personal data and other information collected by Tradewind East Inc in connection with the Services, including personal data and other information submitted by subscribers who has registered to access the Services via Tradewind Messenger (hereinafter referred to as: “the Subscribers”).

Tradewind East Inc receives, collects and processes personal data and other information in order to operate, provide, improve, understand, customize, support and market the Services. The personal data and other information are received, collected and processed when installing, accessing or using the Services.

The personal data and other information received and collected by Tradewind East Inc in connection with the Services is administered by Tradewind East Inc, who has a status of a controller determining the purposes and means for the processing of personal data and other information received and collected in connection with the Services. Tradewind East Inc receives, collects and processes personal data and other information in accordance with the governing law and only to the extent necessary to provide the Services.

To create a user account Subscribers are asked to provide Tradewind East Inc with following personal data and information:

• email address (login to Google Account or Microsoft Account);
• mobile phone number;
• first and last name and/or company name;
• title;
• email addresses and password information for Subscriber’s email accounts;
• city of Subscriber’s residence;
• billing address;

If Subscriber does not provide Tradewind East Inc with above information, he/she will not be able to create an user account and use the Services. The Subscriber may provide Tradewind East Inc with additional profile information including profile picture and general description.

Tradewind Messenger allows the Subscribers to browse and edit photos from Subscriber’s device’s photo library in order to upload a profile picture and other images and/or videos stored within photo library. Tradewind Messenger may only access the Subscribers’ photo library, if they explicitly authorize it to upon request for permission for sharing images and/or videos stored within photo library. Upon Subscriber’s prior explicit approval Tradewind Messenger accesses and records camera sensor and microphone data, which is used for the purpose of capturing images from the device and/or recording voice messages. Tradewind East Inc only collects and processes images explicitly selected by the Subscriber and processes them only for purposes related to setting a profile picture or enabling sending communications on Subscriber’s behalf.

Tradewind Messenger, to the extent permitted by applicable laws, allows the Subscribers to browse and upload contacts stored within Subscriber’s device’s phonebook and within Subscriber’s email accounts, including first and last names and/or company names, phone numbers and email addresses.

Tradewind Messenger may only access the Subscribers’ device’s phonebook and Subscriber’s email accounts, if they explicitly authorize it upon request for permission for sharing contacts stored within Subscriber’s device’s phonebook and within Subscriber’s email accounts.

Upon Subscribers’ consent to access to Subscribers’ device’s phonebook, Tradewind Messenger will track and upload new contacts (including first and last names and/or company names, phone numbers and email addresses) on a daily basis without further notification to the Subscriber.

Upon Subscribers’ consent to access to Subscribers’ email accounts, Tradewind Messenger will track new contacts and upload them on a daily basis subject to obtaining Subscriber’s consent.

The Subscriber can create a contact list within Tradewind Messenger by choosing contacts that are to receive communications via Tradewind Messenger. The Subscriber may manage chosen contacts via Contact Tab in a Tradewind Messenger.

Contact data from the contact list created within Tradewind Messenger are used and processed for sending sale and marketing communications and messages, such as emails, including information on offers for the acquisition and/or sale of real estates.

Tradewind East Inc use and transfer of information received from Google APIs to any other app will adhere to Google API Services User Data Policy, including the Limited Use requirements.

Tradewind East Inc requires each of the Subscribers to have lawful rights to collect, use, and share contact information before providing any information to Tradewind East Inc.

Upon Subscriber’s prior explicit approval Tradewind Messenger accesses Subscriber’s calendar. Tradewind Messenger uses calendar events information to determine Subscriber’s availability for scheduling meetings and to simplify scheduling meetings.

Tradewind East Inc receives, collects and processes customer support and other communications related to the use of the Services, including copies of Subscriber’s messages, any other information Subscriber deems helpful or provides when contacting Tradewind East Inc’s team, respond to surveys, participate in market research activities, participate in telephone conferences with Tradewind East Inc’s representatives, participate in a focus group, contest, activity or event, apply for a job, enroll in a program, interact with Tradewind East Inc’s social media accounts or otherwise communicate with Tradewind East Inc.

Tradewind Messenger enables the Subscribers to send communications and messages, including information on offers for the acquisition and/or sale of real estates to consumer contacts provided by the Subscriber. Tradewind Messenger also enables the Subscribers and third parties, like potential clientele, to communicate and interact with each other using the Services, including via text or voice messages.

Tradewind East Inc stores the communications and messages shared by the Subscriber via Tradewind Messenger on servers located in USA hosted by Amazon Web Services (AWS) (440 Terry Ave N, Seattle, WA 98109, USA), within Supabase proprietary hosted software platform made available by Supabase, Inc. (a Delaware corporation with offices located at 970 Toa Payoh North #07-04, Singapore 318992).

People or businesses the Subscribers interact with using the Services may provide Tradewind East Inc with information about their interactions with the Subscribers. Tradewind East Inc requires each of these businesses to act in accordance with applicable law when providing any information.

Usage and Log Data: Tradewind East Inc collects and uses information about user’s activity on the Services, like service-related, diagnostic, and performance information. This includes information about Subscriber’s activity (including how Subscriber uses the Services, Services settings, how Subscriber interacts with others using the Services, and the time, frequency, and duration of Subscriber’s activities and interactions), log files, and diagnostic, crash, website, and performance logs and reports. This also includes information about when Subscriber registered to use the Services; the features Subscriber uses; profile photo; whether Subscriber is online, when Subscriber last used the Services.

Device Information: Tradewind East Inc automatically collects information about devices accessing the Services, including type of device, manufacturer and model, what operating system is used, the version of the app, device settings, application IDs, unique device identifiers and crash data.

Cookies: Tradewind East Inc uses cookies, text files stored on a user’s device to uniquely identify the user’s browser or to store information or settings in the browser, for the purpose of helping users navigate between pages efficiently and remembering user’s preferences, enabling functionality, helping Tradewind East Inc to understand user activity and patterns, facilitating online advertising and measuring the effectiveness of communication with the user.

If the user does not accept cookies, he/she may not be able to use some portions of the Services.

The personal data and other information received, collected and processed by Tradewind East Inc under this Privacy Policy are used to operate, provide, improve, understand, customize, support, and market the Services, including providing customer support, improving, fixing, and customizing the Services.

The personal data and other information received, collected and processed by Tradewind East Inc under this Privacy Policy are required for the Services to be properly supplied and settled.

Tradewind East Inc also uses received and collected information to understand how people use the Services, evaluate and improve the Services, research, develop, and test new services and features and conduct troubleshooting activities. Tradewind East Inc uses received and collected information to respond to users when contacted.

Tradewind East Inc uses received and collected information to verify accounts and activity, combat harmful conduct, protect users against bad experiences and spam, and promote safety, security, and integrity on and off the Services, such as by investigating suspicious activity or violations of Tradewind East Inc’s terms and policies, and to ensure the Services are being used legally.

Tradewind East Inc uses received and collected information to communicate with users about the Services and let the users know about Tradewind East Inc’s terms, policies, and other important updates. Tradewind East Inc may provide users with marketing for the Services.

Information submitted to Subscribers’ profiles will not be publicly viewable and shall be available only to the Tradewind East Inc. Tradewind East Inc handles all personal and sensitive user data securely, including transmitting it using modern cryptography (for example, over HTTPS).

Within the extent allowed by applicable law submitted personal information will be disclosed to government or law enforcement officials or private parties if Tradewind East Inc is obliged to do it or concerns it necessary:

• in response to lawful requests by public authorities (for example a court order, search warrant or subpoena);
• to satisfy any laws or regulations that apply;
• where the Services are being used in committing a crime, including to report such criminal activity or to share information with other companies and organizations for the purposes of fraud protection, credit risk reduction, and other security precautions;
• to protect the rights or property of Tradewind East Inc and other applicable third parties;
• to enforce this Privacy Policy;
• in case of use of the Services in a manner violating this Privacy Policy or the law in force, Tradewind East Inc shall have the right to use submitted personal data within the scope necessary to establish one’s liability.

Tradewind East Inc will make any legally required disclosures of any breach of the security, confidentiality, or integrity of unencrypted electronically stored “personal data” (as defined in applicable laws related to security breach notification) via e-mail in the most expedient time possible and without unreasonable delay, insofar as consistent with: (i) the legitimate needs of law enforcement; or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

After the Services is finished, Tradewind East Inc may process only those personal data, which are:

• necessary to settle the Services, issue an invoice or make claims for payment;
• necessary to investigate the circumstances of prohibited use of the Services;
• allow to process under applicable acts of law

To simplify the registration and authentication process, Tradewind East Inc uses third-party identity providers, including Google LLC, Microsoft Corporation and Apple Inc. In this case, Tradewind East Inc will be able to access some data stored by these third-party service providers for registration or identification purposes such as name, surname, email address, and profile picture.

Tradewind East Inc works with third-party service providers to provide hosting, serving, storage and telecommunication needs, including without limitation storage of personal data and other information received, collected and processed by Tradewind East Inc under this Privacy Policy.

Tradewind East Inc shall use only such third-party service providers who guarantee an appropriate level of protection of the personal data processed.

Tradewind East Inc stores the communications and messages shared by the Subscriber via Tradewind Messenger on servers located in USA hosted by Amazon Web Services (AWS) (440 Terry Ave N, Seattle, WA 98109, USA) within Supabase proprietary hosted software platform made available by Supabase, Inc. (a Delaware corporation with offices located at 970 Toa Payoh North #07-04, Singapore 318992).

Tradewind East Inc stores contacts uploaded from Subscriber’s device’s phonebook and Subscriber’s email accounts on servers located in USA hosted by Amazon Web Services (AWS) (440 Terry Ave N, Seattle, WA 98109, USA), within Supabase proprietary hosted software platform made available by Supabase, Inc. (a Delaware corporation with offices located at 970 Toa Payoh North #07-04, Singapore 318992). Additionally Tradewind East Inc stores contacts uploaded from Subscriber’s device’s phonebook and Subscriber’s email accounts within Google Cloud Platform (GCP) on servers owned by Google LLC located in USA.

Tradewind East Inc stores uploaded images and videos within Google Cloud Platform (GCP) on servers owned by Google LLC located in USA.

Tradewind East Inc stores personal data and other information received, collected and processed under this Privacy Policy for as long as necessary for the purposes identified in this Privacy Policy, including to provide the Services or for other legitimate purposes, such as complying with legal obligations, enforcing and preventing violations of this Privacy Policy, or protecting or defending Tradewind East Inc’s rights, property, and users. The storage periods are determined on a case-by-case basis that depends on factors like the nature of the information, why it is collected and processed, relevant legal or operational retention needs, and legal obligations.

Subscribers and other users maintain the right of access their personal information, as well as to request to have his personal data supplemented, updated or rectified, or to temporarily or permanently cease the processing of his personal data, if those data are incomplete, outdated or untrue, or if they were collected in violation of legal regulations in force, or if they are no longer necessary for the purpose for which they were collected. In order to do so contact Tradewind East Inc at support@tradewind.co. Subscribers may review and update the personally identifiable information in Subscribers’ profile by logging in and editing such information in the mobile application. If Subscriber decide to delete all of his/her information, Tradewind East Inc may cancel Subscriber’s account.

Tradewind East Inc may ask Subscribers and other users to complete surveys that may be used for research and to improve the Services, although Subscribers and other users have no obligation to respond to them.

Tradewind East Inc is committed to protecting the security of submitted personal information. Tradewind East Inc uses a variety of security technologies and procedures to help protect personal information. Personal information is stored on a server with physical and electronic security features required by legal regulations in force, including utilization of login/password procedures and electronic firewalls designed to block unauthorized access. All the Tradewind East Inc’s employees are obligated by privacy and security policies. The Tradewind East Inc’s security and privacy policies are periodically reviewed and enhanced as necessary, and only authorized individuals have access to submitted personal information.

Any personal data and other information received, collected and processed by Tradewind East Inc under this Privacy Policy will not be sold to any third parties without prior permission.

In order to grant the continuation of performance of the Services, Tradewind East Inc may disclose submitted personal data and other information, to another third party as part of reorganization or a sale of the assets of the Tradewind East Inc’s division or company. Any third party to whom Tradewind East Inc transfers or sells assets will have the right to continue to use the personal data and other submitted information – for the purpose specified herein. Consent to this Privacy Policy followed by submission of personal information represents consent to such transfer.

Tradewind East Inc may at any time make modifications to this Privacy Policy.

Tradewind East Inc will never knowingly collect any personal information about children under the age of 18. If Tradewind East Inc obtains actual knowledge that it has collected personal information about a child under the age of 18, that information will be immediately removed from any access.

Any queries or comments regarding personal data or this Privacy Policy may be submitted at support@tradewind.co