TurtleTrader® Privacy Policy

This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from https://www.turtletrader.com (the “Site”).

Modification Date: March 12, 2024
Effective Date: June 1, 2018

We care about how businesses use our information online, and we care about your privacy. We also value precision and clarity of language, so we organized this Privacy Policy into three distinct segments: 1. For those individuals in the European Union; 2. For those individuals in California; and 3. For those individuals everywhere else.

Please review the segment that applies to you based on where you are located geographically.

Thank you!


A. What Personal Data Do We Collect From You?

Personal data is information that can be used to identify you such as your name, IP address, and email address. We process personal data from you in a number of ways including:

(1) Purchases: Your name, email address, and credit card information although we use a third party known as Stripe to collect and process this data.
(2) Log in: Your name, email address, and password when you log in to your account.
(3) Customer Service: Your name, email address, and reason for contacting us.

B. What Is The Purpose of Processing Your Personal Data?

We collect the information above for the following purposes.

(1) Purchases: Your personal data is used to process payment and provide you Flagship Training.
(2) Log in: Your personal data is used to provide access to your account.
(3) Customer Service: Your personal data is used to evaluate your inquiry and provide you with answers.

C. What Legal Basis Do We Have For Collecting and Processing Your Information?

Websites must have a legal basis for collecting information from individuals located in the European Union. Our legal basis for each of the ways we process your data is as follows.

(1) Purchases: We process your data as part of an allowed contractual transaction.
(2) Log in: A legitimate interest exists for allowing you to access your account. We consider the processing of your login information a legitimate interest because when you seek to login, you expect us to collect information to allow you access to the system and we have a legitimate interest in allowing customers access to their accounts.
(3) Customer Service: A legitimate interest exists for providing you with answers to your questions. When you affirmatively contact us, your expectation is we will use your personal data to reply with an answer and we have a legitimate business interest in providing customers and potential customers with answers to their questions.

D. Who Has Access To The Data We Collect?

We process and access you data as described above through the help of third parties that have the digital infrastructure that we do not and without whom we would be unable to provide Flagship Training including:

These third parties have made contractual promises to not use your personal data in any manner we do not authorize.

E. Cookies and Similar Technologies

We use cookies to track you. This tracking is done to provide you with ease of use such as expediting the login to your account, as well as provide us with information on how people move about the site, what is of interest to them and what is not, and incidental items such as what percentage of users access the site from a personal computer versus a mobile phone. You may block most cookies by adjusting your browser settings as well as responding to the cookie consent notice that appears when you first visit this site. To learn more about this technology, please visit our Cookie Policy.

Cookie declaration last updated on 3/12/24 by Trend Following:

Necessary (1)

Necessary cookies help make a website usable by enabling basic functions like page navigation and access to secure areas of the website. The website cannot function properly without these cookies.

Name: CookieConsent
Provider: www.turtletrader.com
Purpose: Stores the user’s cookie consent state for the current domain.
Expiry: 1 year
Type: HTTP Cookie

Statistics (3)

Statistic cookies help website owners to understand how visitors interact with websites by collecting and reporting information anonymously.

Name: __CJ_session_metadata
Provider: Scribd
Purpose: Contains data about the user’s interaction with the audiobook and document-presentation-tool for statistical purposes.
Expiry: Session
Type: HTTP Cookie

Name: _scribd_session
Provider: Scribd
Purpose: Implements audio-files on the website, and determines how many and who have listened to these files.
Expiry: 3 years
Type: HTTP Cookie

Name: td
Provider: Google
Purpose: Registers statistical data on users’ behaviour on the website. Used for internal analytics by the website operator.
Expiry: Session
Type: Pixel Tracker

Marketing (8)

Marketing cookies are used to track visitors across websites. The intention is to display ads that are relevant and engaging for the individual user and thereby more valuable for publishers and third party advertisers.

Name: _fs_sample_user
Provider: Scribd
Purpose: Presents the user with relevant content and advertisement. The service is provided by third-party advertisement hubs, which facilitate real-time bidding for advertisers.
Expiry: 30 days
Type: HTTP Cookie

Name: _ga
Provider: Google
Purpose: Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitor across devices and marketing channels.
Expiry: 2 years
Type: HTTP Cookie

Name: _ga_#
Provider: Google
Purpose: Used to send data to Google Analytics about the visitor’s device and behavior. Tracks the visitor across devices and marketing channels.
Expiry: 2 years
Type: HTTP Cookie

Name: fbsr_#
Provider: Meta Platforms, Inc.
Purpose: Used to track the user’s interaction with the website’s Facebook chat-widget.
Expiry: Session
Type: HTTP Cookie

Name: fbssls_#
Provider: Meta Platforms, Inc.
Purpose: Collects data on the visitor’s use of the comment system on the website, and what blogs/articles the visitor has read. This can be used for marketing purposes.
Expiry: Session
Type: HTML Local Storage

Name: optimizelyOptOut [x2]
Provider: Optimizely
Purpose: Collects visitor data related to the user’s visits to the website, such as the number of visits, average time spent on the website and what pages have been loaded, with the purpose of displaying targeted ads.
Expiry: Session
Type: HTTP Cookie

Name: scribd_ubtc
Provider: Scribd
Purpose: Collects information on user behaviour on multiple websites. This information is used in order to optimize the relevance of advertisement on the website.
Expiry: 400 days
Type: HTTP Cookie

F. How Long Do We Keep Your Data?

We keep your personal data for different periods of time depending on the reason it was gathered in the first place.

(1) Purchases: We keep your payment data via a third party process for as long as you continue to be a paid user of Flagship Training. Once this is no longer the case, we will hold your information for an additional four years as part of our tax records should an audit arise.
(2) Login: We will maintain your login data for as long as you are a paying user of Flagship Training.
(3) Customer Service: We will hold customer service personal data for a period of four years which covers the statute of limitations should a legal dispute arise between you and us.

G. Your Right To Ask For Corrections, Erasure, And Other Actions

We want you to have control over your data. You have the right to see all the data we have for you, ask for the corrections to the data, ask us to erase the data, object to how we use your data, ask that the data be exported, and ask that we stop automatically processing the data in particular manners. Although we have certain rights to limit your control of data, we believe it is YOUR data so we will liberally comply with your requests whenever possible. We are not a data mining company trying to monetize your personal information. To exercise any of these rights, please contact us.

H. Your Right To Withdraw Consent

We want to emphasize that wherever we’ve asked for your consent to collect or process your personal data, you have the right to withdraw that consent. You can contact us here.

I. Do We Transfer Your Data To Third Countries?

No. We are located in the United States. Your data is collected and held here.

J. Privacy Concerns, Contacting Us, Complaints

You can contact us with any questions or requests you have about these policies or your personal data by contacting us here. If, after contacting us, you feel a privacy issue has not be resolved, you have the right to file a complaint with a Supervisory Authority.

Data Controller
Representative: Michael Covel
Trend Following
11654 Plaza America Drive, Ste 224
Reston, VA 20190

You can contact us by sending a message via our Contact Page or by sending correspondence to: Trend Following, 11654 Plaza America Drive, Ste 224, Reston, VA 20190


A. Do Not Track Signals

Pursuant to the California Online Privacy Protection Act, we hereby disclose that we do not currently honor “do not track” signals issued by browsers or other third party sources.

B. California Eraser Law

If you are an individual under 18 and have provided personal information or content to us in some manner, you have the right to request the deletion of that information pursuant to the “California Eraser Law.” Contact us to make such a request.


A. Privacy Policy Modifications and Updates

We may update and modify this Privacy Policy at any time. In doing so, we will post a notice on the site 30 days before the change goes into effect and forward an email message to you should we have an email address for you. However, you may exercise any rights noted in the new policy before the 30 day period runs and we agree to abide by our obligations as noted in the new policy.

B. Legal Disclosures of Personal Information

We may disclose personal information if required to do so by law or in the good-faith belief that such action is necessary to (1) conform to the edicts of the law or comply with legal process served on us, (2) protect and defend our rights or property or (3) act under exigent circumstances to protect the safety of the public or users of the site.

C. DMCA Disclosures

We comply with the Digital Millennium Copyright Act of 1998. As part of the compliance process, we may be required to disclose whatever information we have for you to a copyright holder who has submitted a complaint to us as a matter of law.

D. Security Measures

We have security measures in place such as Secure Sockets Layer protocols to prevent the loss, misuse, and alteration of the information that we or our vendors obtain from you, but we make no assurances about our ability to prevent any such loss, misuse, to you or to any third party arising out of any such loss, misuse, or alteration. If we suffer a data breach, we will provide you with the appropriate breach notification given jurisdiction and FBI requirements.

E. Third Party Websites

We link to other sites, but please keep in mind that we do not control the privacy policies of those sites. Make sure to review the policies of any such sites before providing your personal information.

F. Sale of Business

Should we sell this site or our business, your personal information will be an asset transferred to the new owner.

If you have any questions about this Privacy Policy, please contact us.