This Privacy Policy explains which personal data Tribe Capital B.V. processes, why, and what your rights are. It applies to our website, checkout, the 1-1 Mentorship Program, the Capital Scaling Program, the Group Coaching Program, our learning platform, community channels and trading journal.
1.Who we are
The controller of your personal data is Tribe Capital B.V., Rietpolderlaan 60, 1398 DC Muiden, the Netherlands, Chamber of Commerce (KvK) number 98397842.
For any privacy question or request, contact us at info@thetribecapital.com.
Our services are intended for persons aged 18 and over. We do not knowingly process data of minors.
2.What we collect, why, on which legal basis, and for how long
We collect only the data we need for each purpose below. After the retention period we delete or anonymise the data, unless a legal claim is pending or the law requires us to keep it longer.
Concluding and performing your agreement: checkout, onboarding, access, support
- Data
- Name, email, phone, country, username, order details, consumer or business status, company and VAT details
- Legal basis (GDPR)
- Performance of contract
- Retention
- 2 years after the agreement ends, to handle complaints and guarantee or conformity claims
Invoicing and accounting
- Data
- Invoices, amounts paid, billing details
- Legal basis (GDPR)
- Legal obligation (Dutch tax law)
- Retention
- 7 years after the end of the financial year, only for data that forms part of our accounting records
Payments and payment disputes
- Data
- Payment status, payment method type, last four digits of a card. Full card details are held by the payment provider, not by us
- Legal basis (GDPR)
- Performance of contract; legitimate interest (handling payment disputes)
- Retention
- Until the period for payment disputes has ended, at most 18 months after the payment
Mentorship and coaching
- Data
- Session bookings and attendance, chat messages with your Educator or coaches, homework and quiz submissions, notes on your progress
- Legal basis (GDPR)
- Performance of contract
- Retention
- 2 years after the agreement ends
Recordings of live group sessions
- Data
- Display name, voice, image, questions asked and charts shared in the session
- Legal basis (GDPR)
- Legitimate interest (making group sessions available as course material to other clients); see section 3
- Retention
- Up to 24 months after the session
Trading journal and performance analysis
- Data
- Trades you enter or import, account statements, read-only account data, performance and risk statistics
- Legal basis (GDPR)
- Performance of contract
- Retention
- Deleted or anonymised 3 months after the agreement ends, unless needed for a pending guarantee assessment or dispute
Assessing the Profitability Support Extension and the Capital Allocation Guarantee
- Data
- Account statements, journal records, assessments, related correspondence
- Legal basis (GDPR)
- Performance of contract
- Retention
- 2 years after the assessment or the end of the agreement, whichever is later
Introductions to a capital allocator (Capital Scaling Program)
- Data
- Track record materials, performance report, contact details
- Legal basis (GDPR)
- Performance of contract, at your request for each introduction
- Retention
- Shared only per request; our own copy follows the trading journal period
Proof of order and acceptance
- Data
- Acceptance of terms, ticked checkout statements with date, time and IP address, order confirmation
- Legal basis (GDPR)
- Legitimate interest (evidence)
- Retention
- 5 years after the agreement ends, the statutory limitation period for contractual claims
Security and preventing misuse
- Data
- Login data, IP address, device and browser data, access logs
- Legal basis (GDPR)
- Legitimate interest (security and protecting our content)
- Retention
- 12 months
Marketing
- Data
- Name, email, interests, interaction with our emails
- Legal basis (GDPR)
- Legitimate interest for existing clients; consent for others. You can unsubscribe at any time
- Retention
- Until you unsubscribe; for leads, 2 years after last contact
Testimonials, reviews and identifiable results in marketing
- Data
- What you post in a testimonial or review section (text, screenshots, images, video) with your name or display name; other identifiable results only with separate consent
- Legal basis (GDPR)
- Consent, given by posting in a section marked for testimonials or separately. You can withdraw it at any time by email, on Discord or through any other channel you use with us
- Retention
- Until you ask us to remove it; we remove it from our own channels within 14 days
Website analytics and advertising
- Data
- Cookie and pixel data, pages visited, referral source
- Legal basis (GDPR)
- Consent where required
- Retention
- As stated in the cookie settings
| Purpose | Data | Legal basis (GDPR) | Retention |
|---|---|---|---|
| Concluding and performing your agreement: checkout, onboarding, access, support | Name, email, phone, country, username, order details, consumer or business status, company and VAT details | Performance of contract | 2 years after the agreement ends, to handle complaints and guarantee or conformity claims |
| Invoicing and accounting | Invoices, amounts paid, billing details | Legal obligation (Dutch tax law) | 7 years after the end of the financial year, only for data that forms part of our accounting records |
| Payments and payment disputes | Payment status, payment method type, last four digits of a card. Full card details are held by the payment provider, not by us | Performance of contract; legitimate interest (handling payment disputes) | Until the period for payment disputes has ended, at most 18 months after the payment |
| Mentorship and coaching | Session bookings and attendance, chat messages with your Educator or coaches, homework and quiz submissions, notes on your progress | Performance of contract | 2 years after the agreement ends |
| Recordings of live group sessions | Display name, voice, image, questions asked and charts shared in the session | Legitimate interest (making group sessions available as course material to other clients); see section 3 | Up to 24 months after the session |
| Trading journal and performance analysis | Trades you enter or import, account statements, read-only account data, performance and risk statistics | Performance of contract | Deleted or anonymised 3 months after the agreement ends, unless needed for a pending guarantee assessment or dispute |
| Assessing the Profitability Support Extension and the Capital Allocation Guarantee | Account statements, journal records, assessments, related correspondence | Performance of contract | 2 years after the assessment or the end of the agreement, whichever is later |
| Introductions to a capital allocator (Capital Scaling Program) | Track record materials, performance report, contact details | Performance of contract, at your request for each introduction | Shared only per request; our own copy follows the trading journal period |
| Proof of order and acceptance | Acceptance of terms, ticked checkout statements with date, time and IP address, order confirmation | Legitimate interest (evidence) | 5 years after the agreement ends, the statutory limitation period for contractual claims |
| Security and preventing misuse | Login data, IP address, device and browser data, access logs | Legitimate interest (security and protecting our content) | 12 months |
| Marketing | Name, email, interests, interaction with our emails | Legitimate interest for existing clients; consent for others. You can unsubscribe at any time | Until you unsubscribe; for leads, 2 years after last contact |
| Testimonials, reviews and identifiable results in marketing | What you post in a testimonial or review section (text, screenshots, images, video) with your name or display name; other identifiable results only with separate consent | Consent, given by posting in a section marked for testimonials or separately. You can withdraw it at any time by email, on Discord or through any other channel you use with us | Until you ask us to remove it; we remove it from our own channels within 14 days |
| Website analytics and advertising | Cookie and pixel data, pages visited, referral source | Consent where required | As stated in the cookie settings |
We do not ask for special categories of personal data. Please do not share health or similar sensitive information in sessions or community channels unless you choose to.
If you do not provide the data needed for your agreement, we cannot deliver the Program.
3.Recordings, community and trading data
Recordings. Live group sessions are recorded and transcribed. 1-on-1 sessions are not recorded. You are told at the start of each group session that it is recorded. Recordings are made available on our learning platform only to clients with Platform access, for up to 24 months after the session; after that they are deleted or anonymised.
You can take part fully without being identifiable: join with camera and microphone off and an anonymous display name, and ask your questions in the session chat. Written questions are answered in the session in the same way as spoken ones. You can also ask us at info@thetribecapital.com to remove or mask identifiable parts of a recording; we will do so where technically possible, and you can object to the processing at any time (section 7).
Community. Messages you post in community channels are visible to other members and to our team. Community channels run on third-party platforms that are also controllers of your data under their own privacy policies (section 4).
Trading data. Trading data can reveal a lot about your financial situation, so we limit it. Only the Educators assigned to you and staff who need it for the Program have access. We ask only for the data needed for feedback, statistics, guarantee assessments and leaderboards. Leaderboards show only a display name and score. We delete or anonymise trading data within the period in section 2. We use only anonymised, aggregated data to improve our programs.
No automated decisions. We do not take decisions with legal or similarly significant effect based solely on automated processing. Guarantee assessments are made by a person.
4.Who we share data with
We do not sell personal data. We use the following providers:
Whop, Inc.
- What for
- Checkout, payments, membership access
- Role
- Independent controller for the data it collects as platform; we receive the purchase details
- Location
- United States
- Transfer safeguard
- Whop's own safeguards under its privacy policy
Thinkific Labs Inc.
- What for
- Course hosting and learning platform
- Role
- Processor
- Location
- Canada
- Transfer safeguard
- Standard Contractual Clauses in Thinkific's data processing addendum
Discord Netherlands B.V. (Discord Inc.)
- What for
- Community channels and live group sessions
- Role
- Independent controller
- Location
- Netherlands and United States
- Transfer safeguard
- Discord's own safeguards: EU-US Data Privacy Framework and Standard Contractual Clauses
Google (Google Workspace)
- What for
- Email, calendar, file storage, and 1-on-1 calls and live group sessions via Google Meet
- Role
- Processor
- Location
- EU and United States
- Transfer safeguard
- Standard Contractual Clauses under Google's Cloud Data Processing Addendum
Hetzner Online GmbH
- What for
- Server hosting for our own applications
- Role
- Processor
- Location
- Germany
- Transfer safeguard
- Not applicable (within the EEA)
Netlify, Inc.
- What for
- Website hosting
- Role
- Processor
- Location
- United States
- Transfer safeguard
- EU-US Data Privacy Framework, with Standard Contractual Clauses as fallback
BOND Administratie & Advies
- What for
- Bookkeeping, VAT and tax returns
- Role
- Processor
- Location
- Netherlands
- Transfer safeguard
- Not applicable (within the EEA)
| Provider | What for | Role | Location | Transfer safeguard |
|---|---|---|---|---|
| Whop, Inc. | Checkout, payments, membership access | Independent controller for the data it collects as platform; we receive the purchase details | United States | Whop's own safeguards under its privacy policy |
| Thinkific Labs Inc. | Course hosting and learning platform | Processor | Canada | Standard Contractual Clauses in Thinkific's data processing addendum |
| Discord Netherlands B.V. (Discord Inc.) | Community channels and live group sessions | Independent controller | Netherlands and United States | Discord's own safeguards: EU-US Data Privacy Framework and Standard Contractual Clauses |
| Google (Google Workspace) | Email, calendar, file storage, and 1-on-1 calls and live group sessions via Google Meet | Processor | EU and United States | Standard Contractual Clauses under Google's Cloud Data Processing Addendum |
| Hetzner Online GmbH | Server hosting for our own applications | Processor | Germany | Not applicable (within the EEA) |
| Netlify, Inc. | Website hosting | Processor | United States | EU-US Data Privacy Framework, with Standard Contractual Clauses as fallback |
| BOND Administratie & Advies | Bookkeeping, VAT and tax returns | Processor | Netherlands | Not applicable (within the EEA) |
The trading journal is our own software, operated by Tribe Capital.
We also share data with:
- Educators and staff engaged by us, bound by confidentiality, to the extent they need it;
- other clients, limited to what appears in group sessions, recordings, community channels and leaderboards, as described in section 3;
- third-party providers you choose to use, such as BrightFunded for a challenge or a capital allocator for the Capital Scaling Program, only at your request; they act as independent controllers under their own privacy policies;
- banks, card issuers and payment processors, where we need to respond to a payment dispute;
- advisers, collection agencies, courts and authorities, where needed to enforce our rights or where the law requires it;
- a successor of our business, in case of a merger, sale or restructuring.
5.Transfers outside the EEA
Where a provider in section 4 processes data outside the European Economic Area for us, we rely on the safeguard stated for that provider. Where a provider acts as an independent controller, it is responsible for its own transfers. You can ask us for a copy of the relevant safeguards.
6.How long we keep data
The retention period for each purpose is stated in the table in section 2. After that period we delete or anonymise the data. We keep data longer only while a legal claim is pending or where the law requires it.
7.Your rights
Under the GDPR you have the right to:
- access your personal data and receive a copy;
- have incorrect data corrected;
- have data deleted, where we have no legal ground to keep it;
- restrict processing or object to processing based on legitimate interest, including direct marketing;
- receive data you provided in a portable format;
- withdraw consent at any time, without affecting earlier processing.
Send your request to info@thetribecapital.com. We may ask you to verify your identity. We respond within one month, which the law allows us to extend by two months for complex requests.
You may also lodge a complaint with the Dutch Data Protection Authority (Autoriteit Persoonsgegevens, autoriteitpersoonsgegevens.nl) or with the authority in your country of residence. We would appreciate the chance to resolve it with you first.
8.Security
We take appropriate technical and organisational measures to protect your data, including access controls, encrypted connections and limiting access to those who need it. You are responsible for keeping your login details secret. If a data breach is likely to result in a high risk to you, we will inform you without undue delay.
9.Cookies
Our website and third-party platforms use cookies and similar technologies. Functional cookies are needed for the site and checkout to work. Analytics and advertising cookies and pixels are placed only with your consent where the law requires it. You can withdraw consent or delete cookies through the cookie settings or your browser.
10.Changes
We may update this Privacy Policy. The current version is always available on our website and checkout page, with the date it was last updated. We notify you by email of material changes.
11.Contact
Tribe Capital B.V., Rietpolderlaan 60, 1398 DC Muiden, the Netherlands
info@thetribecapital.com