PRIVACY POLICY

Effective as of Jun 30th 2021

This Privacy Policy describes how Tradewith collects, uses, stores and discloses information that we obtain about you.

Tradewith and “we” “our” or “us” refer to Tradewith Co., a Delaware corporation.  This Privacy Policy applies to your access and use of any of our products or services (each and together, the “Services”), including your access to and through our website and Tradewith’s mobile device applications, and the information we collect about you. This Privacy Policy covers “Personal Information,” which is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly to you or your household.

By accessing any of our Services, including setting up an account with us, you agree to our collection, use, storage and disclosure of your information and the practices and policies described in this Privacy Policy.

As set forth in our Terms of Service, Tradewith’s Services are provided to persons who are at least eighteen (18) years of age.  We do not knowingly collect or solicit Personal Information from anyone under the age of 18.  If you believe that we have received Personal Information from anyone under the age of 18, please contact us at support@tradewith.co.

This Privacy Policy does not apply to the practices of companies that we do not own or control, including third parties that provide services, such as payment processors, brokerage firms or application providers that connect you with other services. Third parties are separately responsible for their services, including their information collection practices and privacy policies.

What Personal Information do we collect?

Personal Identifiers. When you register to use our Services, you are required to provide an email address, your first and last name and possibly other personal identifying information, and you will be asked to establish a user name and password. If you are a Publisher receiving payment from us, you also may provide us with additional contact information, a tax identification number and payment information that is your Personal Information.

Third Party Credentials and Information. We use third party services and applications to permit you to access your third party brokerage accounts, and those services, whether provided directly or indirectly by your broker obtain your log-in credentials to permit you to access your brokerage account.

Device, Online and Other Identifiers. When you use devices such as your computer or mobile phone, we obtain the name of your internet service provider (ISP), your internet protocol (IP) address and your location.

Internet, Browser, Network and Similar Activity.  When you use our Services, we and third parties use technologies that enhance your use of the Services but also identify you, store your preferences and provide us and third parties with a variety of tracking data. These technologies, such as cookies and web beacons, identify your computer or device, the website from which you visit us, the pages on our website or Apps that you visit and in what sequence, the date and length of your use of any Services and provide us with other statistical information. These technologies, such as cookies or web beacons, may not contain or reveal your Personal Information; but if you provide us with your Personal Information, it can be linked to the anonymous data stored in the technology (e.g., cookies and/or web beacons).

What Additional Information should you consider?

Cookies are small text files that are placed on your internet browser or device when you visit websites, including when you view our advertisements on other websites. Cookies allow us to recognize your browser or device and identify how and when pages are visited.  You may be able to change preferences on your browser or device to prevent or limit the use of cookies, but that may limit your ability to use the website or device and certain aspects of our Services.

Third parties, such as a broker or Publisher, may also transmit cookies, web beacons or similar technologies.  The cookies placed by third parties may continue to track your activities on your computer or device after you have stopped using our Services, including our Site or Apps, and third parties may not honor “Do Not Track” requests you have set on your browser, computer or device.

A “Do Not Track” option allows you to signal to operators of websites, applications and services that you do not wish for them to track certain of your activities over time and across websites and applications.  We do not currently support Do Not Track signals or similar mechanisms.  For more information about Do Not Track, visit donottrack.us.

How do we use Personal Information?

As part of our business activities, we collect, use and share your Personal Information, including device and online identifiers, information about your internet, browser and network activity and location data. If you provide us with your Personal Information, we use, transfer and share that information within our company and with our third party service providers to provide our Services to you.  We do not sell Personal Information to third parties.  We allow third party service providers to collect and use Personal Information as part of our business activities, including for advertising, marketing and promotion activities.  We also share aggregated data and information with third parties (though not in a manner that identifies you personally).  For example, we may use your information for the following purposes:

• Providing Services: We use your email and other Personal Information to provide you with Services, to inform you and to respond to you. Our use of your Personal Information includes for security and administrative purposes. We share your Personal Information with third parties with whom we have a business relationship as necessary to provide you with Services, such as sharing your access information with application providers to permit you to access your brokerage account if you choose. We use your brokerage account information as part of our Services such as when you use our tools to analyze your investments. We do not share any of your brokerage account information with third parties unless directly related to providing our Services.
• Improving Our Services: We and third party service providers we engage use and share your device, online and other identifiers and Personal Information about your internet, browser network and similar activity to review, measure and improve our Services, including our technical performance and for security purposes.
• Marketing: We use your Personal Information to market, promote and advertise our Services to you, and to inform you of Services which may be of interest to you, such as subscriptions from Publishers. We may use your location information to show you advertising targeted for your location.
• Legal Process: We may share your Personal Information with third parties as permitted by, or to comply with, applicable law, which includes responding to subpoenas or other legal processes, protecting against fraud or other unlawful activity and cooperating with law enforcement or regulatory authorities.

We may keep your information, including Personal Information, for at least as long as it serves the purposes for which it was collected, and we may keep your information indefinitely.

To whom do we Disclose your Personal Information?

We will not share with any third party your Personal Information except as described in this Privacy Policy. Specifically, we may share your Personal Information when we have your permission, or in any of the following situations without your permission:

• We will disclose information, including your Personal Information, to affiliates or third-parties who are performing through or in connection with our Services, such as when a payment processor is completing a payment transaction. When we disclose Personal Information to a third party, it will be only to the extent related to the transaction or service and the third party is required to use the Personal Information only for those purposes.
• We may disclose information, including your Personal Information, to third parties whom we engage to provide us with professional services, such as accountants, auditors, attorneys and similar advisors, subject to standard confidentiality obligations.
• We will disclose the results of aggregate information or blind data about the Users of our Services to third parties. In such circumstances, we do not disclose Personal Information.
• We may disclose information, including your Personal Information, including by sale or transfer to a third party, as part of a merger, acquisition or other sale or transfer of all or substantially all of our assets or business.
• We may disclose information, including your Personal Information, to third parties if needed to enforce any agreements with us; to conduct any investigation of potential breaches of terms of any agreements; to address fraud, security or technical issues; to protect the rights, property or safety of Tradewith or others; to protect against harm to any element of our Services; or as required by law, such as in connection with suspected illegal activity or to respond to a subpoena, court order or other legal process. We reserve the right to release information to law enforcement or other government officials, as we, in our sole discretion, deem necessary or appropriate.

What Information Security Measures do We Use?

To help protect your privacy, we employ reasonable physical, technical, and procedural measures intended to protect your Personal Information.  For example, we use specialized technology, such as firewalls; we review our procedures and train our personnel on security risks; we protect information during transmission through various methods, including where appropriate, encryption; and we use third party service providers that encrypt the transmission of sensitive information such as when you transmit payment information.

You also protect your privacy and Personal Information by preventing unauthorized access to your accounts and access codes, such as protecting your passwords for your devices, applications and accounts.

While we seek to protect the privacy of your information, including Personal Information, we do not guarantee complete security.  ANY ASPECT OF TECHNOLOGY USED AS PART OF OUR SERVICES, WHETHER SOFTWARE, HARDWARE, NETWORKS OR OTHERWISE, FROM TIME TO TIME, MAY EXPERIENCE BREACHES OF SECURITY OR OTHER PROBLEMS BEYOND OUR CONTROL.

Any disclosure, transmission or sharing of your information, including your Personal Information, is done at your own risk. See our Terms of Service for disclaimers of warranties and limitations of liability.

How Do I Get Additional Help With My Personal Information?

We respect your right to access and make decisions about your Personal Information.  You can update or change your Personal Information through your Account.  You can contact us with any concerns about your Personal Information. If you have any questions or comments about your Personal Information or this Privacy Policy, contact us at support@tradewith.co.

If you have a request relating to your Personal Information, we may not be able to fulfill it, such as if it interferes with our obligations under contract or by law, if we cannot verify your identity, if it involves disproportionate cost or effort.  We will respond and provide you with an explanation.

If you stop using our Services, we may retain your information, including as necessary to fulfill our obligations under contract or by law, to enforce our agreements and to continue using aggregate data.

What law governs this Privacy Policy?

You agree that any dispute over privacy or the terms contained in this Privacy Policy will be construed and governed by the laws of the State of New York without reference to the state’s conflict laws, and will be subject to the dispute resolution clause contained in our Terms of Service (www.tradewith.co/terms).

How will we make Changes to this Privacy Policy?

In Tradewith’s sole discretion, we may change this Privacy Policy at any time, and the changes shall be effective immediately upon posting to the Site. Your continued use of the Services after the changes have been made is your acceptance to this Privacy Policy as changed.