Privacy Policy — Cyber Wolfdog Trading

Version 2.3
Last updated: 14 October 2026
This version applies from its date of publication.

Cyber Wolfdog Trading (“CWDT”, “we”, “us”, “our”) respects your privacy and processes personal data in accordance with applicable privacy legislation, including the General Data Protection Regulation (GDPR/AVG).

This Privacy Policy explains what personal data we may process, why we process it, how it may be used and protected, how long it may be retained, when it may be shared and what privacy rights you have.

It applies to:

• ebooks.cyberwolfdogtrading.com and related CWDT webpages;

• eBooks and other digital products;

• newsletters and Website forms;

• memberships and learning environments;

• customer support;

• CWDT Technical Managed Services and other technical services;

• communications through email, WhatsApp, Telegram, MQL5 and other CWDT communication channels.

2. Personal Data We May Process

The personal data CWDT processes depends on the products or services you use.

Website, newsletter and enquiries

This may include:

• name;

• email address;

• telephone number;

• address information where voluntarily provided or required;

• newsletter subscription information;

• subscription date, time and source;

• consent records and technical identifiers such as IP address where available;

• enquiries, messages and attachments you provide.

eBooks and digital purchases

This may include:

• name;

• email address;

• billing address and country;

• company information where applicable;

• VAT information where applicable;

• product, price, tax and order information;

• payment status and transaction/order reference;

• order date and timestamps;

• download and access information required for product delivery, support, security and prevention of misuse or unauthorised sharing.

Payments are processed through external payment providers.

CWDT does not store full payment-card or bank-payment credentials.

Memberships and learning environments

Where applicable, this may include:

• name;

• email address;

• account or login information;

• membership or access level;

• course or digital-content access;

• learning progress where supported by the applicable platform;

• administrative and support information.

CWDT Technical Managed Services and technical support

Where necessary for a requested service, registration or applicable legal obligation, CWDT may process:

• name and contact details;

• address information;

• date of birth;

• country of residence;

• fiscal residence;

• nationality where required;

• company details;

• VAT and Chamber of Commerce information;

• tax identification information where legally required;

• broker, VPS, trading-platform or other technical account information;

• verification status;

• account balance and equity information;

• open and closed positions;

• trading history;

• technical configurations;

• service records;

• access or login credentials required to provide, maintain or recover a service.

A Dutch citizen service number (BSN) is processed only where CWDT has a specific legal basis requiring or permitting such processing.

CWDT may manually compare information supplied by a Client with relevant broker, VPS, trading-platform or other technical-account information where necessary to verify the Client or correctly connect the requested service.

Identification documents are not routinely retained.

Where a Client specifically requires assistance with a registration or verification process, an identification document may be handled temporarily where necessary. It is deleted when the relevant process has been completed unless a specific legal obligation requires further retention.

Such assistance does not transfer the Client's own KYC, identification or verification responsibilities to CWDT.

Information visible within a broker or technical environment that is irrelevant to CWDT's service is not intentionally copied or retained.

Communications and support

CWDT may process relevant communications through email, WhatsApp, Telegram, MQL5 and other communication channels.

Video calls and remote-support sessions are not recorded by CWDT.

Temporary support notes are removed when no longer necessary unless they contain information that must reasonably be retained for contractual, administrative, evidentiary or legal purposes.

Website and technical information

Depending on your cookie choices, this may include:

• IP address;

• browser and device information;

• pages visited;

• approximate location derived from technical information;

• cookie identifiers;

• Website usage and performance information.

CWDT does not intentionally collect unnecessary special-category personal data such as information concerning health, religion, political opinions, ethnicity or sex life.

If unnecessary sensitive information is supplied without being requested and there is no lawful reason to retain it, CWDT may delete it.

Most personal data is obtained directly from you. Limited administrative, transaction or technical information may also be received from payment providers, membership platforms, brokers or other providers involved in a service requested by you.

CWDT does not purchase personal-data or marketing lists.

Where personal data is necessary to enter into or perform a contract, failure to provide the required information may mean that CWDT cannot provide the requested product or service.

4. eBooks, Digital Products and CWDT Technical Managed Services

eBooks and digital products

Purchase information may be used to:

• process and document your purchase;

• deliver the digital product;

• send order confirmations;

• provide customer support;

• administer requested discounts or promotions;

• comply with tax and accounting obligations;

• prevent fraud, abuse or unauthorised distribution.

CWDT Technical Managed Services

CWDT Technical Managed Services and comparable technical Client services are strictly 18+.

CWDT may manually verify identity, age, contact details or the relationship between the Client and a relevant broker, VPS, trading or technical account where necessary.

Where account or technical access is required, that access is provided or authorised by the Client.

CWDT does not independently obtain access to a Client's broker account without the Client's involvement.

Broker or platform environments may contain identity, financial, payment or other information beyond what CWDT requires.

CWDT processes only information reasonably relevant to the requested service and does not intentionally copy or retain unrelated identification, banking, payment or withdrawal information merely because it is visible in such an environment.

Where CWDT processes personal data on behalf of a business client as a processor, CWDT and the client conclude a data processing agreement under Article 28 GDPR before the processing starts.

Clients may revoke technical access.

Where access is necessary to provide the requested service, withdrawal or restriction of that access may make it impossible for CWDT to continue the service until appropriate access has been restored and the technical environment has been assessed.

6. Cookies, Analytics and Website Tracking

CWDT uses cookies and similar technologies for Website functionality, security, preferences, analytics and, where applicable, marketing.

CWDT uses Cookiebot by Usercentrics to manage cookie preferences.

Cookie categories may include:

• Necessary cookies — required for Website operation and security;

• Preference cookies — remember optional user preferences;

• Analytics cookies — provide information about Website usage and performance;

• Marketing cookies — may be used for advertising and campaign measurement.

Where consent is legally required, non-essential cookies are not activated until the visitor has given the relevant consent.

The Website uses Google Analytics for general Website statistics, subject to applicable cookie and consent requirements.

Meta/Facebook Pixel may be enabled in connection with Meta/Facebook advertising campaigns and is subject to applicable consent requirements.

CWDT does not upload Client lists to Meta for Custom Audience creation.

Visitors can:

• accept optional cookies;

• reject non-essential cookies;

• select individual cookie categories;

• change or withdraw their choices later.

Cookie preferences can be reopened through the permanent privacy/cookie control available on the Website.

The Cookiebot cookie information provides further details regarding detected cookies, purposes, providers and applicable durations.

Withdrawal of consent does not affect processing that was lawful before consent was withdrawn.

8. Retention, Termination and Backups

CWDT does not retain personal data longer than reasonably necessary for the purpose for which it was processed, subject to applicable statutory obligations.

Financial and fiscal administration

Relevant financial and administrative records are retained for the period required by applicable tax and accounting laws.

Relevant Dutch basic administration is generally retained for 7 years.

Specific records may be subject to a longer period, including a 10-year retention period where applicable under relevant tax rules.

Newsletter information

Newsletter information is retained while the subscription remains active.

After unsubscribing, CWDT may retain a minimal suppression record necessary to respect the opt-out.

Communications

Relevant email, WhatsApp, Telegram and other business communications are retained only for as long as legally required or reasonably necessary for the applicable contractual, administrative, evidentiary or legal purpose.

Identification and verification

Temporary identification-document copies used during a registration or verification process are deleted when the process has been completed unless a specific legal obligation requires further retention.

Other identification or verification information is retained only as long as necessary for the relevant service or legal obligation.

Technical access and credentials

Technical access credentials required for an active service may be retained securely while necessary for service delivery, maintenance or emergency access.

Following termination, such credentials are removed from CWDT's active systems no later than six weeks after termination, except where temporary longer retention is strictly necessary because of an unresolved security incident or legal dispute.

Other Client-specific technical information and configurations are removed when no longer reasonably necessary for the applicable technical, contractual, administrative, evidentiary or legal purpose.

Security, download and access logs

Security, download and access logs are retained for a limited period necessary for security, digital-product delivery and the prevention of abuse or unauthorised sharing.

Learning environments

Learning-account information and progress may be deleted at the user's request where supported by the relevant platform and where no applicable legal retention requirement prevents deletion.

Deletion remains subject to the technical deletion and retention processes of the relevant platform provider.

Backups

CWDT maintains secured and encrypted backups for continuity, security and recovery purposes.

Personal data removed from active systems may temporarily remain within protected backups until those backups are overwritten or removed through the normal backup-rotation process.

Backups are not ordinarily used to reintroduce information that has already been lawfully deleted from active systems.

Where information is necessary to establish, exercise or defend legal claims, investigate a security incident or comply with a legal obligation, relevant information may be retained for as long as that purpose lawfully requires.