PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AND WHAT CHOICES AND RIGHTS YOU HAVE IN THIS REGARD. IF YOU DO NOT AGREE WITH THE TERMS AND CONDITIONS OF THIS POLICY, YOU SHOULD NOT ACCESS OR USE THE SITE.
TradersPost, Inc. (“TradersPost” also referred to as “we,” “us,” and “our”) respects the sensitive nature of the personal information you provide to us. We are committed to protecting the privacy and security of the personal information we collect, use, share, and otherwise process as part of our business. We also believe in transparency, and we are committed to informing you about how we treat your personal information. We have created this Policy, together with our Terms of Service, and any documents referenced therein, in order to demonstrate our commitment to the privacy of those who visit our website, TradersPost.io (the “Site”), and use our services.
When does this Policy apply? This Policy describes our online information collection, storage and disclosure practices and the choices you have regarding how your personal information is collected and used by us. By accessing and using the Site or by otherwise signaling your agreement when the option is presented to you, you consent to the collection, use and disclosure of information described in this Policy. This Policy only governs the Site and our platform, and it does not govern off-line data collection. Any materials submitted through the Site and your use of the Site are subject to the Terms of Service.
Residents of the EU/EEA. Residents of the European Economic Area (“EEA”), which includes the member states of the European Union (“EU”), should consult the “Rights of EEA Residents” and “International Data Transfers” sections of this Policy for more information about provisions that may apply to them.
We collect, receive and process the following personal information from you for the purposes set forth below and in the “Other Processing Activities” section of this Policy. If you are a user in the EU or the EEA, for purposes of the EU General Data Protection Regulation, 2016/679 (the “GDPR”), we act as a data controller with respect to this information. We collect information from you via the Site, and we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources.
Is entry of personal information required? You may choose not to provide us with any personal information, and you may still access and use much of the Site. However, if you do not provide any personal information, you will not be able to access any portions of the Site that require your personal information.
| Category | Types of Data and Purpose |
|---|---|
| Contact Information |
When you visit our Site, request our services, or contact us, we may collect or receive your first and last names, mailing address, telephone number, and email address.
We process Contact Information to provide our Site and services, to honor our terms of use and contracts, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. |
| Account Information |
In order to access and use certain features of the Site, you must first complete a registration. When you create an account and register with us, in addition to your Contact Information, we collect your username and password.
We process Account Information to provide our Site and services, to honor our terms of use and contracts, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our customer relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. |
| Payment Information |
If you choose to purchase a paid subscription from us, in addition to your Contact Information and Account Information, we collect, via our payment processor, your billing address and your credit card number, security code, and expiration date. By submitting your Payment Information, you expressly consent to the sharing of this information with our third-party payment processers and other service providers (including vendors who provide fraud detection services). We do not store your Payment Information.
We process Payment Information to bill and fulfill orders, to process payments, to honor our terms of use and contracts, and to manage the data associated with those purposes. The legal basis for this processing is consent or, where applicable, the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. |
| Broker Tokens |
If you subscribe to our services, you can link your broker accounts to our platform. Most integrations occur via OAuth, and we do not receive any information in this scenario. Some integrations are based on tokens, and we will briefly process your user credentials for the brokerage account in order to receive a token from the broker for the integration. We will retain the tokens, but we will not retain your brokerage account credentials.
We process Broker Tokens to provide our Site and services, to honor our terms of use and contracts, to ensure the privacy and security of our Site and services, and to maintain our databases and back-ups. The legal basis for this processing is consent or, where applicable, the performance of a contract between you and us. |
| Social Network Information |
You may connect with us through a third-party social network, such as Facebook, Twitter, LinkedIn and other networks (each, a “Social Network”). If you choose to do so, we may collect information from your profile on such Social Network, such as your name, username, and email address. In addition, our Site offers features that will allow you to share information from our Site to a Social Network or share information from our Social Network sites. If you decide to use such features, they may allow the sharing and collection of information both to and from such Social Network so you should check the privacy policy of each Social Network before using such features.
We process Social Network Information to provide our Site and services, to manage our relationships with you, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business and the proper management of our customer relationships. |
| Cookies and Similar Technologies |
When you visit the Site, we collect cookies and use similar technologies as described in the “Cookies and Similar Technologies” section of this Policy. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly. Please see the “Cookies and Similar Technologies” section of this Policy for more information.
We process Cookies and Similar Technologies to operate the Site, to serve you the content and functionality you request, and to ensure the privacy and security of our Site and services. The legal basis for processing of strictly necessary cookies is our legitimate interests in the proper administration of our Site and business. |
| Usage Data |
When you visit our Site, we automatically collect information from your browser or device, which includes the date and time of your visit as well as your location, Internet Protocol (IP) address, unique device identifier, device type, browser type, domain server, access time, and data about which pages you visit.
We process Usage Data to analyze use of the Site and our services, to operate the Site, to serve you the content and functionality you request, to ensure the privacy and security of our Site and services, to develop new services, to enhance your experience, to track visits to the Site, and to provide you with a more personal and interactive experience on the Website, and for usage analytics. The legal basis for this processing is our legitimate interests in monitoring and improving our Site and services. |
| Your Communications and Feedback |
If you contact us, in addition to your Contact Information, we will collect the information in your message and other information needed to respond to your inquiry or to answer your question. If you receive email communications from us, we use certain tools to capture data related to if/when you open our message or click on any links or banners it contains. Other information collected through this email tracking feature includes: your email address, the date and time of your clicks, a message number, a tracking URL number, and a destination page.
We process Your Communications and Feedback to provide our Site and services, to honor our terms of use and contracts, to ensure the privacy and security of our Site and services, to maintain our databases and back-ups, to manage our relationships with you, to improve our customer service, to communicate with you, and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site and business, the proper management of our relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract. |
Other Processing Activities. In addition to the processing activities described above, but only where permitted by applicable law, we may process personal information (1) when required by law; (2) to create, use, retain, or disclose de-identified or aggregated data; or (3) when necessary for:
We may process your personal information in connection with any of the purposes and uses set out in this Policy on one or more of the following legal grounds:
We do not use personal information for making any automated decisions affecting or creating profiles other than as described herein.
First and Third-Party Cookies
A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” or “permanent” cookie). “Session” cookies are temporarily stored on your hard drive and only last until they expire at the end of your browsing session. “Persistent” or “permanent” cookies remain stored on your hard drive until they expire or are deleted by you. Local stored objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you’re visiting, and they can only be read by that site. Third-party cookies are set by a party other than that website.
Other Similar Technologies
In addition to cookies, there are other automatic data collection technologies, such as Internet tags, web beacons (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as users navigate through and interact with a website:
What Cookies and Similar Technologies Are in Use and Why Do We Use Them?
Google Tag Manager. We use Google Tag Manager, which allows marketed website tags to be managed using an interface. The tool itself (which implements the tags) does not use cookies and does not register identifiable data. The tool causes other tags to be activated which may, for their part, register personal data under certain circumstances. Google Tag Manager does not access this information. Google Tag Manager is subject to the Google Privacy Policy located at https://www.google.com/intl/en/policies/privacy.
Other Cookies. We also use the following first-party cookies:
| Cookie | Description | Category | Retention |
|---|---|---|---|
| PHPSESSID | Used for authentication and remembering the logged-in user | Necessary | Session |
| REMEMBERME | Used for authentication and remembering the logged-in user | Necessary | 365 days |
Other Third-Party Technologies
Some third parties may use automated data collection technologies to collect information about you when you browse the Internet. The information they collect about your online browsing activities over time and across different websites and other online services may be associated with your personal information and used to provide you with targeted content. We do not control these third parties’ technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible party directly or consult their privacy policies.
Choices About Cookies
Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may choose to not allow certain cookies via the cookies consent banner or you may set your browser to refuse all or some types of cookies or to alert you when cookies are being sent by website tracking technologies and advertising. You may adjust your browser settings to opt out of accepting a “persistent” cookie and to only accept “session” cookies, but you will need to log in each time you want to enjoy the full functionality of the Site.
Please be aware that, if you decline the use of cookies, you may not have access to the full benefits of the Site. In addition, adjusting the cookie settings on the Site may not fully delete all of the cookies that have already been created. To delete them, visit your web browser settings after you have changed your cookie settings on the Site. Additional information is provided below about how to disable cookies or manage the cookie settings for some of the leading web browsers:
To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website at: https://www.macromedia.com/support/documentation/en/flashplayer/help/help09.html. For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.
How and When Is Your Information Shared With Other Parties? We may share your information in the following contexts, but, we will not share your Personal Information if such sharing is prohibited by applicable privacy and data protection law. We do not sell, trade or license Personal Information about our users for marketing purposes.
| Category | Context |
|---|---|
| Corporate Affiliates | We may share your information with our corporate subsidiaries and affiliates and with their respective officers, directors, employees, accountants, attorneys and agents. |
| Service Providers | We may engage third parties to help us carry out certain functions, such as account processing, client services, or other data collection relevant to our business. We may also use third parties to deploy marketing to our customers and users, to help us to administer the Site, to support our provision of services requested by you, to provide technical support, to provide payment processing, and to assist with other legitimate purposes permitted by law. Personal Information is shared with these third parties only to the extent necessary for them to provide services to us. |
| Legal Obligations and Rights | We may share your information with law enforcement or other government agencies as required by law or for the purposes of limiting fraud. We reserve the right to disclose your information when we believe that disclosure is necessary to protect our rights; to comply with the law; or to comply with a subpoena, warrant, judicial proceeding, court order or other legal process. We further reserve the right to disclose any of your information that we believe, in good faith, appropriate or necessary to establish or exercise our legal rights; to take precautions against liability; to investigate and defend against any third-party claims or allegations; to assist government enforcement agencies; to protect the security or integrity of the Site or our services; to protect the rights, property or personal safety of us, our users or others; and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, or a violation of our Terms of Service or other contracts. |
| Acquisitions and Similar Transactions | We may share your information in connection with a corporate reorganization or transaction, such as a divestiture, merger, consolidation, acquisition, dissolution, or asset sale, or in the unlikely event of bankruptcy. For example, if another company acquires us, we will share your personal information with that company. |
| Disclosures with Consent | We may ask if you would like us to share your information with other third parties who are not described elsewhere in this Policy. We will only disclose your information in this context with your consent. |
| De-identified or Aggregated Data | We may disclose aggregated information about our users, and information that does not identify any specific individual, such as groupings of demographic data or customer preferences. |
We retain the personal information we receive as described in this Policy for as long as you use our services or as necessary to fulfill the purpose(s) for which it was collected, to provide our services, to resolve disputes, to establish legal defenses, to conduct audits, to pursue legitimate business purposes, to enforce our agreements, and to comply with our business requirements and applicable laws.
We take reasonable steps to delete the personal information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may also decide to delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your personal information is contrary to our legal obligations or business objectives. When we delete personal information, it will be removed from our active servers and databases; but, it may remain in our archives when it is not practical or possible to delete it.
To the extent permitted by law, we may retain and use anonymous and aggregated information for performance reporting, benchmarking, and analytic purposes and for product and service improvement.
We take commercially reasonable steps to protect personal information against unauthorized disclosure, use, access, alteration, or loss. You can learn more about our security practices here. We do not store or save your financial information. From time to time, we review our security procedures to consider appropriate new technology and methods.
However, no security system is perfect, and no data transmission over the Internet can be guaranteed to be 100% secure. Therefore, while we strive to protect user information, we cannot guarantee or warrant the security of any information you transmit to us or from the Site. You engage in such transmissions at your own risk. We cannot promise that your personal information will remain absolutely secure in all circumstances.
The safety and security of your personal information also depends on you. If you use the Site, you are responsible for maintaining the confidentiality of your account and for restricting access to your computer or device, and you agree to accept responsibility for all activities that occur under your account. You are responsible for keeping your password confidential. If you believe your Personal Information is being improperly used by us or any third party, please immediately notify us via email at [email protected].
If a security breach compromises your data, we will notify you and any applicable regulator when we are required to do so by applicable law and in accordance with our agreements with our data controller customers.
Please use the “Contact Us” details at the end of this Policy to exercise your rights and choices under this Policy.
Communication Preferences. If you no longer wish to receive communications from us via email, you may opt-out of certain types of communications (as described below) by clicking the “unsubscribe” link at the bottom of our emails or by contacting us at the “Contact Us” details provided at the end of this Policy and providing your full name, mailing address, phone number and email address so that we may identify you in the opt-out process. Once we receive your instruction, we will promptly take action.
Cookies. You may set your browser to refuse all or some browser cookies or to alert you when cookies are being set. For more information on how to modify your browser settings to block or filter cookies, visit http://www.aboutcookies.org/. You may learn more about internet advertising practices and related consumer resources at http://www.aboutads.info/consumers/, http://www.networkadvertising.org/choices, and http://youronlinechoices.eu/.
Online Tracking Signals. We do not currently recognize browser settings or signals of tracking preferences, which may include “Do Not Track” instructions. “Do Not Track” is a web browser setting that seeks to disable the tracking of individual users’ browsing activities. We adhere to the standards set out in this Policy and do not currently respond to “Do Not Track” signals.
Accuracy and Updating Your Personal Information. Our goal is to keep your personal information accurate, current, and complete. We ask that you keep the Personal Information that you provide to us current and that you correct any information you have provided to us by contacting us at [email protected]. You represent and warrant that all information you provide to us is true and correct and relates to you and not to any other person. If any of the personal information you have provided to us changes, please update it in your user/account profile, or let us know via the “Contact Us” details at the end of this Policy. For instance, if your email address changes, you may wish to let us know so that we can communicate with you. If you become aware of inaccurate personal information about you, you may want to update your information. We are not responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete personal data that you provide to us.
Complaints. If you believe that your rights relating to your personal information have been violated, you may lodge a complaint with us by contacting us via the “Contact Us” details at the end of this Policy.
California Residents. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once a calendar year information about the information we shared, if any, with other businesses for direct marketing uses. At present, we do not share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing, if any, will be included in our response. As part of the California Online Privacy Protection Act, all users of our site may make any changes to their information at any time by contacting us at [email protected].
Nevada Residents. You may submit a verified request to us at the “Contact Us” details provided at the end of this Policy to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request. We will respond to your request in accordance with Nevada law.
If you are located in the EU or EEA, you have the following rights under the GDPR. All requests should be sent to the address noted in the “Contact Us” section of this Policy, and we will fulfill requests to the extent required by applicable law.
We are located and established in the United States and, therefore, your personal information may be transferred to, stored, or processed in the United States. While the data protection, privacy and other laws of the United States might not be as comprehensive as those in your country, we take necessary and appropriate steps to protect the privacy and security of your personal information. By using the Site or requesting services from us, you understand and consent to the collection, storage, processing, and transfer of your information to our facilities in the United States and those third parties with whom we share it as described in this Policy.
When storing, hosting, or otherwise processing your information (including personal data), we may send such data outside of the EU and the EEA. When we transfer information to the United States or other countries, we do so for the purposes set forth in this Policy and in accordance with applicable law. We rely on recognized legal bases to lawfully conduct cross-border/international transfers of personal information outside of the EU and EEA, such as your express informed consent to do so (as noted above), when transfer is necessary for us to deliver services pursuant to an agreement between us and you, for the conclusion or performance of a contract concluded in the interest of the data subject between the controller and another natural or legal person, or when the transfer is subject to safeguards that assure the protection of your personal information, such as the European Commission’s approved standard contractual clauses.
This Policy only applies to the Site, and it does not apply to any third-party websites or applications.
The Site may contain links to, or media and other content from, third-party websites. These links are to external websites and third parties with that have their own privacy policies. If you follow any links that direct you away from the Site, including links to social media sites or to other Site, this Policy will not apply to your activity on the other sites you visit. Because of the dynamic media capabilities of the Site, it may not be clear to you which links are to the Site and which are to external, third party websites. If you click on an embedded third-party link, you will be redirected away from the Site to the external third-party website. You can check the URL to confirm that you have left this Site.
We cannot do not (i) guarantee the adequacy of the privacy and security practices employed by or the content and media provided by any third parties or their websites, (ii) control the privacy policies or the privacy practices of any third parties regarding their independent collection or use or your personal information, or (iii) endorse any third party information, products, services or websites that may be reached through embedded links on this Site.
Any personal information provided by you or automatically collected from you by a third party will be governed by that party’s privacy policy and terms of use. If you are unsure whether a website is controlled, affiliated, or managed by us, you should review the privacy policy and practices applicable to each linked website.
The Children’s Online Privacy Protection Act (“COPPA”), as well as other data privacy regulations, restrict the collection, use, or disclosure of personal information from and about children on the Internet. The Site is restricted to the use of adults over the age of majority in their place of residence. No portion of the Site is directed to children under the age of 18, and no one under the age of 18 may access, browse, or use the Site or provide any information to or on the Site. Consequently, we do not knowingly collect personal identifying information from any person under the age of 18. If we learn that we have collected personal information from a child under age 18 without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and delete that information as quickly as possible. If you are a parent or guardian of a child under 18 years of age and you believe your child has provided us with Personal Information, please contact us at [email protected].
For more information about COPPA, please visit the Federal Trade Commission's website at: https://www.ftc.gov/enforcement/rules/rulemaking-regulatory-reform-proceedings/childrens-online-privacy-protection-rule.
We reserve the right to add to, change, update, or modify this Policy at any time to reflect any changes to how we treat your information or in response to changes in law. In the event we make changes to this Policy, such policy will be re-posted on this page, with the date such modifications were made indicated on the top of the page. If we make material changes to how we treat your information, we may contact you to inform you about the revisions with a link to the revised Policy or notify you through a notice on the homepage of the Site for a reasonable period of time. All changes are effective on the date listed at the top of this page and will apply to all information that we have about you.
You are expected to, and you acknowledge and agree that it is your responsibility to, carefully review this Policy prior to using the Site, and from time to time, so that you are aware of any changes. Your continued use of the Site or our services after the “Last Updated” date indicates your acceptance of the changes and your continued consent to our processing of your personal data according to the terms of the then-current Policy. If at any point you do not agree to any portion of this Policy, then you should immediately stop using the Site and the services. Because this Policy contains legal obligations, we encourage you to review this Policy carefully.
For more information, or if you have any questions concerning this Policy or our information collection, storage and disclosure practices, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.