Privacy Policy

Introduction

trumandfwo B.V. ("we," "our," or "us") is committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, process, and protect your information when you visit our website trumandfwo.live or use our flash sale services. As a company registered in the Netherlands, we comply with the General Data Protection Regulation (GDPR) and applicable Dutch data protection laws.

By using our services, you consent to the collection and use of your information as described in this policy. If you have any questions about this Privacy Policy, please contact us at privacy@trumandfwo.live.

Data Controller

trumandfwo B.V. is the data controller for your personal data. Our contact details are:

Data Collection

The data we collect includes personal information that you voluntarily provide to us and information automatically collected when you use our website and services. We collect this information to provide you with our flash sale services, improve your experience, and comply with legal obligations.

Information You Provide

• Name and contact information (email address, phone number, postal address)
• Account registration details
• Communication preferences and VIP list signup information
• Purchase history and transaction details
• Customer service communications and feedback
• Marketing preferences and consent records

Automatically Collected Information

• IP address and device information
• Browser type and operating system
• Website usage data and navigation patterns
• Cookies and similar tracking technologies (see our Cookie Policy)
• Referral sources and marketing attribution data

How We Use Your Information

We explain how we use your information for various purposes related to our flash sale services and business operations. The use of your data is based on legitimate legal grounds under GDPR, including contract performance, legitimate interests, and your consent where required.

Primary Uses

• Processing and fulfilling flash sale orders and transactions
• Providing customer support and responding to inquiries
• Sending VIP list notifications and exclusive flash sale alerts
• Personalizing your shopping experience and product recommendations
• Processing payments and preventing fraudulent transactions
• Improving our website functionality and user experience

Legal Basis for Processing

• Contract Performance: Processing orders, delivery, and customer service
• Legitimate Interest: Website analytics, fraud prevention, and business operations
• Consent: Marketing communications, VIP list membership, and optional cookies
• Legal Obligation: Tax records, accounting, and regulatory compliance

Data Sharing and Disclosure

We do not sell, trade, or rent your personal information to third parties. We may share your data only in specific circumstances and with appropriate safeguards in place.

Service Providers

We work with trusted third-party service providers who assist us in operating our business, including:

• Payment processors and financial institutions
• Shipping and logistics partners
• Email marketing and communication platforms
• Website hosting and analytics services
• Customer support and help desk systems

Legal Requirements

We may disclose your information when required by law, regulation, or legal process, or to protect the rights, property, or safety of trumandfwo, our customers, or others.

Data Retention

We retain your personal data only for as long as necessary to fulfill the purposes for which it was collected, comply with legal obligations, resolve disputes, and enforce our agreements. Our retention periods are based on the nature of the data and applicable legal requirements.

Retention Periods

• Account Data: Retained while your account is active and for 3 years after closure
• Transaction Records: Retained for 7 years for accounting and tax purposes
• Marketing Consents: Retained until consent is withdrawn
• Website Analytics: Aggregated data retained for 2 years
• Customer Service Records: Retained for 3 years for quality assurance

Your Rights Under GDPR

As a data subject under GDPR, you have specific rights regarding your personal data. You can exercise these rights by contacting us at privacy@trumandfwo.live.

Your Rights Include

• Right of Access: Request a copy of the personal data we hold about you
• Right to Rectification: Request correction of inaccurate or incomplete data
• Right to Erasure: Request deletion of your personal data in certain circumstances
• Right to Restrict Processing: Request limitation of how we process your data
• Right to Data Portability: Request transfer of your data to another service provider
• Right to Object: Object to processing based on legitimate interests or for marketing
• Right to Withdraw Consent: Withdraw consent for processing that requires it

We will respond to your requests within one month. If you are not satisfied with our response, you have the right to lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens).

Data Security

We implement appropriate technical and organizational security measures to protect your personal data against unauthorized access, alteration, disclosure, or destruction. Our security measures include:

• Encryption of data in transit and at rest
• Regular security assessments and updates
• Access controls and employee training
• Secure payment processing systems
• Regular backups and disaster recovery procedures

International Data Transfers

As a Netherlands-based company serving EU customers, we primarily process data within the European Economic Area (EEA). When we do transfer data outside the EEA, we ensure appropriate safeguards are in place, such as adequacy decisions or standard contractual clauses approved by the European Commission.

Cookies and Tracking

We use cookies and similar technologies to enhance your browsing experience, analyze website traffic, and deliver personalized content. For detailed information about our use of cookies, please see our Cookie Policy.

Children's Privacy

Our services are not intended for individuals under the age of 16. We do not knowingly collect personal data from children under 16. If we become aware that we have collected personal data from a child under 16, we will take steps to delete such information promptly.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by posting the updated policy on our website and updating the "Last Updated" date. For significant changes, we may also send you a direct notification.

Contact Us

If you have any questions about this Privacy Policy, wish to exercise your rights, or need to contact us regarding your personal data, please contact us using the following information: