Privacy Policy

This Privacy Policy explains how Lechugas BV, operating as "Subversion Trades" ("we", "us", or "our"), collects, uses, and protects your personal information when you use our sports trading services and content.

We respect your privacy and are committed to protecting your personal data. This Privacy Policy will inform you about how we look after your personal data and tell you about your privacy rights under applicable data protection laws, including the General Data Protection Regulation (GDPR).

Lechugas BV, operating as Subversion Trades, is the controller and responsible for your personal data.

Contact Details:

We may collect, use, store, and transfer different kinds of personal data about you:

• Identity Data: Name, username or similar identifier
• Contact Data: Email address, Telegram username
• Financial Data: Payment information (processed by our payment processors)
• Transaction Data: Details about payments to and from you and other details of services you have purchased from us
• Technical Data: Internet protocol (IP) address, browser type and version, time zone setting, browser plug-in types and versions, operating system and platform
• Usage Data: Information about how you use our website and services
• Trading Interaction Data: Information about which trades you view, follow, or interact with to improve our service
• Performance Statistics: Anonymized data about trade performance and outcomes for service improvement and analysis

We do not collect any Special Categories of Personal Data about you (this includes details about your race, ethnicity, religious beliefs, sexual orientation, political opinions, health information, etc.).

We collect personal data through:

• Direct interactions: When you subscribe to our service, contact us, or join our Telegram group
• Automated technologies: As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions, and patterns
• Third parties: We receive personal data from various third parties such as:
  • Payment processors (Stripe, PayPal, etc.)
  • Telegram (for group membership)

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Performance of Contract: To provide our sports trading services to you
• Legitimate Interests: To operate and improve our business and services
• Legal Obligation: To comply with a legal or regulatory obligation

Purposes for which we will use your personal data:

• To register you as a new customer
• To process and deliver our services
• To manage payments, fees, and charges
• To manage our relationship with you
• To deliver relevant content and experiences
• To analyze trade performance and user engagement patterns
• To monitor Telegram group interactions for service improvement and community management
• To maintain trading performance statistics (in anonymized form) for service improvement
• To use data analytics to improve our website, services, and user experience
• To protect our services

We may share your personal data with:

• Service Providers: Including payment processors, hosting providers, and other technology providers who process your personal data as processors on our behalf
• Professional Advisers: Including lawyers, bankers, auditors, and insurers who provide consultancy, banking, legal, insurance, and accounting services
• Regulators and Authorities: Who require reporting of processing activities in certain circumstances

We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

We operate internationally and serve customers from around the world. This means your personal data may be processed in countries outside the European Economic Area (EEA) where data protection laws may differ from those in your country of residence.

For EEA, UK, and Swiss Users

When we transfer your personal data outside these regions, we ensure a similar degree of protection by implementing at least one of the following safeguards:

• We transfer data to countries that have been deemed to provide an adequate level of protection by the European Commission or relevant authorities
• Where we use certain service providers, we may use specific approved standard contractual clauses which give personal data similar protection to what it has in Europe
• For transfers to the US, we work with service providers who are Privacy Shield certified or use alternative approved mechanisms

For Users Outside Europe

If you access our services from outside Europe, please be aware that your information will be transferred to and processed in the Netherlands and other countries where our service providers may be located. These countries may have data protection rules different from those of your country.

By using our services, you acknowledge that your personal data may be transferred to our facilities and to third parties as described in this Privacy Policy. Regardless of your location, we apply the same core data protection principles and strive to comply with the highest standards of data protection.

We have implemented appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need to know.

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements.

In some circumstances, you can ask us to delete your data (see Your Legal Rights below).

Under the GDPR, you have the following rights in relation to your personal data:

• Right to Access: Request access to your personal data.
• Right to Rectification: Request correction of your personal data.
• Right to Erasure: Request erasure of your personal data. We will comply with requests to delete your personal data unless we are legally required to retain certain information (such as transaction records for tax purposes). Upon request, we will delete your contact information, Telegram username, and any other personal data that is not subject to legal retention requirements.
• Right to Restrict Processing: Request restriction of processing your personal data.
• Right to Data Portability: Request the transfer of your personal data.
• Right to Object: Object to processing of your personal data.
• Rights Related to Automated Decision Making: Object to automated decision-making.

You will not have to pay a fee to exercise any of these rights. However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer if your request is particularly complex or if you have made a number of requests. In this case, we will notify you and keep you updated.

Our website uses cookies and similar technologies to distinguish you from other users of our website. This helps us to provide you with a good experience when you browse our website and also allows us to improve our site.

A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer. Cookies contain information that is transferred to your computer's hard drive.

We use the following cookies:

• Strictly Necessary Cookies: Required for the operation of our website.
• Analytical/Performance Cookies: To recognize and count the number of visitors and to see how visitors move around our website.
• Functionality Cookies: To recognize you when you return to our website.

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies.

We may update this Privacy Policy from time to time. We will notify you of significant changes by posting the new Privacy Policy on our website and, where feasible, by sending you a notification.

If you have any questions about this Privacy Policy or our privacy practices, please contact us at:

Email: [email protected]

If you are in the EU, you also have the right to make a complaint at any time to your local supervisory authority for data protection issues.