TRADE WIND BUSINESS PRIVACY POLICY
Last Updated: October 1, 2025
Welcome to the Trade Wind Business website. This Privacy Policy explains how we collect, use, disclose, and otherwise process your personal information in connection with our www.tradewindsbusiness.com website (the “Website”) and the game services offered through this Website (the “Services”). Please note, if you are an employee or a student of an educational institution with whom we have a direct business relationship (e.g., if registration of our Services is a college class requirement), the collection and processing of your personal information by the institution may be governed by other privacy laws, such as the federal Family Educational Rights and Privacy Act (FERPA).
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PRIVACY HIGHLIGHTS
This summary provides key points from our Privacy Policy. You can find more details about any of these topics by clicking the respective links in our Table of Contents.
What personal information do we collect?
When you visit our Website or otherwise interact with us, we collect and process personal information so you may register to use our Services. We also collect and process personal information so we can share information we think you will find beneficial, and to help us improve and administer our Website and Services.
With whom do we share your personal information?
We do not sell your personal information. We may share information with our service providers and with other third parties, including advertisers, as defined in this Policy.
How do we keep your information safe?
We have administrative, technical and physical safeguards in place to protect your personal information. However, no electronic transmission is 100% secure; and, as such, we cannot guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to circumvent our security efforts and improperly access your information.
What are your privacy rights?
Depending on where you are located geographically, applicable privacy laws may give you certain rights regarding your personal information. See the section below entitled “What are your privacy rights?” for details on those rights and how to exercise them.
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Table of Contents
Who are we?
What is personal information?
How do we collect personal information from you?
What personal Information do we collect from you and how do we use it?
Cookies and other technologies
With whom do we share your personal information?
How do we store and protect your personal information?
How long do we retain your personal information?
What are your privacy rights?
Children’s privacy
Links to other websites and services
How to exercise your privacy rights
Contact us
Changes to the Policy
Who are we?
Dualiti Interactive LLC (“Dualiti”, “we”, “our”, “us”) is the legal entity that manages and operates the website www.tradewindbusiness.com. When we independently collect your personal information through this Website or our Services, we are acting as a “Controller” of your personal information. A “Controller” is an entity that determines the purposes and means of processing of your personal information. This Privacy Policy applies only to our independent privacy and data processing practices when we act as a Controller of your personal information.
We may also collect and process your personal information as part of providing Services to another Controller entity (i.e., an educational institution). In this instance, we are acting as a “Processor” of your personal information. This Privacy Policy does not apply when we are a Processor of your personal information. Instead, the Controller’s Privacy Policy will apply and we will adhere to processing instructions set forth by the Controller.
What is Personal Information?
When we use the term “personal information” in this Privacy Policy, we mean any data or information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular natural person or household or any other data or information that constitutes “personal data”, “personal information,” or “personally identifiable information” as those terms are defined under applicable privacy laws.
How do we collect personal information from you?
We collect information in three ways: (1) we collect the information you provide to us, (2) we automatically collect certain information (for example, through our Website) and (3) we collect information from third parties. Each of these collection practices is described further below.
What personal information do we collect from you and how do we use it?
We collect the information you provide to us. During your visit to our Website, you may choose to provide us with certain information in order to:
Register a Services Account. You may create a Services account through our Website. In order to process your account, we collect information from you, including: your name, email address, and any password you wish to use for accessing your account. If you are a professor, we will also request your employer information.
Contact Us. If you contact us through the “Contact Us” form provided, you will be asked to provide certain information to help us assist you with your stated inquiry. In order to communicate with you concerning this request, we also ask that you provide us with basic contact information.
We automatically collect certain information. When visiting our Website, we automatically collect information about your computer hardware and software. This information can include: your IP address, browser type, domain names, access times and referring website addresses. This information is used for the operation of the Website, to maintain quality of the service, and to provide general statistics regarding use of our Website and Services.
Cookies and other technologies
We use cookies to allow us to personalize your visits, keep track of your preferences and learn about the way in which you use our Website. A cookie is a small file that is placed on your computer when you visit our Website and allows is to recognize you as a user. We may employ both “Essential” and “Non-essential” cookies. Essential cookies are necessary to the effective operation of our Website and make the interaction between you and the Website faster and easier. Non-essential cookies are not required for a website to function but are used for other purposes, such as analytics or advertising.
We also use web beacons, which allow us to count users who have visited our Website (and particular pages on the Website) and to recognize users by accessing our cookies. In addition, a web beacon can be used in HTML-formatted email to determine responses to our communications and measure their effectiveness.
We may participate in behavioral-based advertising. If we do, a third-party will place a cookie on your browser, or use a web beacon, to collect information about your use of our Website and Services so that they can provide advertising about products and services tailored to your interests. That advertising may appear on our Website or on other websites you visit.
We may also use services hosted by third parties, such as Google Analytics, a web analytics service provided by Google, Inc., to assist in providing our Services. Google Analytics uses cookies and other tracking technologies to help us analyze how users use the Website. The information generated by the cookie or other tracking technology about your use of the website (including your IP address) will be transmitted to, and stored by, Google on their servers. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on Website activity for us and providing other services relating to Website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. By using the Services, you consent to the processing of data about you by Google in the manner and for the purposes set out above. To opt out of tracking by Google Analytics, click here.
We also collect information from third parties.
We may also collect information about you from third parties to operate, maintain, and provide to you the features and functionality of the Website and Services, as well as to communicate directly with you, such as to send you email messages about Services that may be of interest to you.
With whom do we share your information?
We may share information collected about you in the following ways:
(1) With service providers. We work with certain third parties who provide services to us, such as managing visitor/customer information, managing our marketing and promotions activities, managing certain information technology systems, and conducting other activities of the kind described elsewhere in this Privacy Policy on our behalf. In such cases, we may disclose your personal information to such service providers, who act as processors of your data on our behalf. We do not authorize any of these service providers to make any use of your information other than for our benefit.
(2) With analytics service providers and advertisers. We may permit third parties to use cookies, web beacons, and similar tracking technologies on our Website. Such parties may collect information about how you use our Website and other websites over time and across different services. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, and better understand your online activity. Information collected in this fashion may be used for targeted marketing purposes – namely, to deliver advertisements targeted to your interests and preferences. To learn about your choices regarding this sharing of your information please see “How to exercise your privacy rights” section below.
(3) With third parties for legal reasons. We would share information about you if we reasonably believe that disclosing the information is needed to: (i) comply with any valid legal process, governmental request, or applicable law, rule, or regulation; (ii) investigate, remedy, or enforce potential violations of our Terms of Use or Privacy Policy; (iii) protect the rights, property, and safety of us, our users, or others; or (iv) detect and resolve any fraud or security concerns.
(4) With third parties as part of an acquisition or liquidation. If we are involved in a merger, asset sale, financing, corporate divestiture, reorganization, or acquisition of all or some portion of our business to another company, or if we undergo liquidation or bankruptcy proceedings, we may share your information with that company before and/or after the transaction closes or the proceedings are completed.
(5) Aggregated or de-identified information with third parties. We may also share with third parties, such as advertisers, aggregated or de-identified information and we may permit our third-party providers to further use, sell, license, distribute, or disclose de-identified data. Aggregated or de-identified information does not identify you and, as such, is not considered personal information.
How do we store and protect your personal information?
We take reasonable precautions, including the implementation of administrative, technical and physical safeguards, to protect your information. Please keep in mind that the internet is not a 100% secure medium for communication, and we cannot guarantee that the information collected about you will always remain private when using our Website. As a result, while we strive to protect your personal information, we cannot guarantee the security of information you transmit to us, and you do so at your own risk.
How long do we retain your personal information?
We will usually store the personal information we collect about you for no longer than necessary to fulfill the purposes for which it was collected, and in accordance with our legitimate business interests and applicable law. However, if necessary, we may retain personal information for longer periods of time, until set retention periods and deadlines expire. For instance, where we are required to do so in accordance with legal, tax and accounting requirements set by law, regulation or government authority.
To determine the appropriate duration of the retention of personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of personal information and if we can attain our objectives by other means, as well as our legal, regulatory, tax, accounting and other applicable obligations.
Once retention of the personal information is no longer necessary for the purposes outlined above, we will either delete or deidentify the personal information or, if this is not possible (for example, because personal information has been stored in backup archives), then we will securely store the personal information and isolate it from further processing until deletion or deidentification is possible.
What are your privacy rights?
In accordance with applicable privacy law, and depending upon the jurisdiction in which you reside, you may have some or all of the following rights in respect of your personal information:
Right of access. You may have the right to obtain: (i) confirmation of whether, and where, we are processing your personal information; (ii) information about the categories of personal information we are processing, the purposes for which we process your personal information and information as to how we determine applicable retention periods; (iii) information about the categories of recipients with whom we may share your personal information; and (iv) a copy of the personal information we hold about you.
Right of portability. You may have the right, in certain circumstances, to receive a copy of the personal information you have provided to us in a structured, commonly used, machine-readable format that supports re-use, or to request the transfer of your personal information to another person.
Right to rectification or correction. You may have the right to obtain rectification or correction of any inaccurate or incomplete personal information we hold about you.
Right to deletion or erasure. You may have the right, in some circumstances, to require us to delete or erase your personal information.
Right to opt-out. You may have the right to opt-out of certain processing activities. For example, you may have the right to opt-out of the use of your personal information for targeted advertising purposes, or to “sell” or “share” your personal information with third parties in certain contexts.
Right to control over automated decision-making or profiling. You may have the right to direct us not to use automated decision-making or profiling for certain purposes.
Right to withdraw consent. If we process your personal information based on your consent, you may have the right to withdraw your consent. If you withdraw your consent, this will not affect the lawfulness of our use of your personal information before your withdrawal.
Right to appeal. In the event that we decline to take action on a request exercising one of your rights set forth above, you may have the right to appeal our decision.
You may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. To exercise any applicable rights, please refer to the “How to exercise your privacy rights” section below.
Children’s Privacy
Our Website and Services are not directed to, and we do not intend to, or knowingly, collect or solicit personal information from children under the age of 18. If an individual is under the age of 18, they should not provide us with any personal information either directly or by other means. If a child under the age of 18 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. If we learn that any personal information we collect has been provided by a child under the age of 18, we will promptly delete that personal information.
Links to other websites and services
Our Services may include links to third-party websites. This Policy does not apply to, and we are not responsible for, any personal information practices of third-party websites, online services or the practices of other third parties. To learn about the personal information practices of third parties, please visit their respective privacy notices.
How to exercise your privacy rights
Please submit a request as set forth in the “Contact Us” section below. Before processing your request, we may need to verify your identity and confirm you are entitled to the applicable privacy rights. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. If we are unable to comply with all or a portion of your request, we will explain the reasons for declining to comply with the request. We will respond to your request as required under applicable privacy laws, generally within 45 days, unless we require more time, in which case we will provide you notice.
In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent’s authority to act on your behalf.
Contact us
If you wish to exercise any of your privacy rights or have any questions about this Notice, please contact us at:
Attn: Privacy
Dualiti Interactive LLC
77 Court St.
Newton, Massachusetts 02458
Changes to the Policy
We may update this Policy from time to time. When we make changes, we will change the date at the beginning of this Policy. If we make material changes to this Privacy Policy, we will take reasonable efforts to notify individuals by email to their registered email address, by prominent posting on our Website, or through other appropriate communication channels. All changes shall be effective from the date of publication unless otherwise provided.