Simpler Trading – Privacy Policy

 

Last Updated: June, 2023

 

Simpler Trading respects privacy and is committed to protecting personal information.  This Privacy Policy (the “Policy”) explains our practices for handling information we may collect and use about website visitors, customers, participants in the Simpler Trading online community, and others with whom we interact in providing our products and services.  This Policy applies to information you provide to us through our websites, simplertrading.com (the “Site”), when you communicate with us, when you post comments in our online trading chatrooms or social media pages, and through our other interactions with you.  It describes the types of personal information we may receive, how we may use and disclose the information, and certain rights and options individuals may have regarding their information.  Use of our Site is also subject to our Terms and Conditions, which are available here.

 

Important Information About This Policy

 

While we always aim to provide complete and transparent information about how we process your personal information, we reserve the right to amend or update this Policy from time to time or to create additional policies in order to accurately reflect changed circumstances or new legal requirements.  As a result, it is important that you read this Policy closely so that you are fully aware of how and why we are using your personal information.

 

To assist us in ensuring that we can provide the most accurate information possible, we ask that you check this Policy for updates. We also ask that where we have an ongoing relationship with you and any of the data you have provided becomes no longer accurate that you keep us informed of this so we can amend our records accordingly.  By providing us with personal information or using our website, you expressly consent to the information-handling practices described in this Policy.  If you do not agree with this Policy, please do not use our website or provide us with your information.

 

Information We Receive

 

1. Personal Information

 

For the purposes of this Policy, “personal information” is any information that identifies, relates to, or can be used to contact a particular individual. The types of personal information we receive includes the following categories.

 

• Contact information – first name, last name, email address, physical address, billing address, and telephone number.
• Site and Service Information – users name and password, information regarding your trading room usage, comments posted on online trading chatrooms, and your usage of tools available through our Site (such as the Squeeze Pro, Daily Price Movement Range, and others).
• Transactional information – details about your transactions with us, including method of payment, payments received, payment details, transaction history, and other information relating to the products and services you have purchased.
• Marketing information – details regarding informational and promotional materials you may have requested or received from us (such as trade alerts, our newsletter, and weekly watchlist), the products and services in which you are interested, your receipt of information and promotional communications, and information on your marketing or communication preferences.
• Communication information – copies of communications and inquiries you have submitted to us, including through email, calls, and features available on our Site.
• Device and usage information – details regarding how and when you use our Site, including the device used to connect to our Site or software, your IP address and device identifier, the frequency and duration of your usage, the pages you view, what websites or search terms referred you to our website, and information about your interaction with our Site.

We collect this information when you visit or navigate our Site, fill in forms on our Site, request and receive a communications from us (such as trade alerts, our newsletter, and weekly watchlist), use any the tools available on our Site, post comments in our online trading chatrooms,  engage in transactions with us, communicate with us (including by phone, email, or otherwise), visit or engage with our social media pages, participate in surveys or sponsored activities, or otherwise provide us with personal information.  Failure to provide us with your personal information means we cannot use it for the purposes set forth below in the section titled “How We Use Your Personal Information.”

Please note that we may aggregate or anonymize the foregoing types of information such that they are no longer capable of identifying you, in which case they are no longer considered “personal information.”  We may also collect information about you from third-party sources and information about you that is publicly available. 

1. Automatically Collected Usage and Device Information

 

1. Overview of Cookies and Other Technologies Used on the Site

Like most websites, our Site uses various technologies to automatically collect information about visitors.  Those technologies include:   

• Cookies. Cookies are small text files that a website transfers to a visitor’s device for recordkeeping purposes.  We use cookies to personalize visitors’ experiences on our website, provide content that we believe may be of interest, track visitor trends and patterns, engage in marketing and advertising, and otherwise analyze our Site traffic.   For further information about cookies, including how to refuse cookies, please visit allaboutcookies.org.  Please note that if cookies are disabled, you may not be able to enjoy certain features of our Site.
• Log Files and Device Identifiers. We use log files to track actions occurring on the Site and collect data about visitors, including IP address, browser type, Internet service provider, referring/exit pages, date/time stamps, and device identifiers.
• Web beacons and other technologies. Our App may use other tracking tools, including web beacons (also known as clear gifs, pixel tags, and single-pixel gifs), which are small electronic images embedded in content and email messages that are not ordinarily visible to users.  Web beacons allow us to track pages and content accessed and viewed by users, as well as to monitor email readership.
•   Our Site may also use third-party analytics tools such as Google Analytics.  You can find more information about how data is collected and processed in connection with the Google Analytics service here.  You can also read Google’s privacy policy here.

The information collected through these technologies may be combined with personal information or aggregated with other information on Site visits.  We may share information about your use of our Site with our advertising and analytics partners, who may combine it with other information that you previously provided to them.

 

2. Specific Types of Cookies

 

We use the following types of cookies on our website.  Other than “strictly necessary cookies,” we will only place these cookies on your computer or device where you have consented to us doing so (except where otherwise permitted by law).  Note some of these cookies are temporary and deleted as soon as you close your browser.  These are known as “session cookies.” Other cookies are stored on your computer or device until they expire or you remove them.  These are known as “persistent cookies.”

 

• Strictly Necessary Cookies. These cookies are necessary for our website to function and cannot be turned off or disabled.  These cookies are usually only set in response to specifc actions you take on the site.
• Performance Cookies. These cookies allow us to count visits and traffic sources to our website so that we can measure and improve its performance.  They assist us in understanding how visitors interact with our website.  For example, they allow us to see which pages are the most and least popular on our website, the frequency of visits to specific pages, how visitors come to our website (e.g., whether they clicked a link from a search engine), and information on the devices and browsers used to access our site.  The information collected by these cookies is aggregated and, therefore, anonymous.  Disabling these cookies will not allow us to recognize you when you visit our website.
• Functional Cookies. These cookies enable the website to provide certain functionality and personalization.  They may be set by us or third-party providers whose service we have added to our pages.  Disabling these cookies may result in some aspects of the website not displaying or functioning properly.
• Targeting Cookies. These cookies may be set through our site by advertising partners.  They may be used to create a profile of visitors’ interests and to show relevant advertising to visitors when they are on other websites.  These cookies are able to identify your browser and internet device.  Disabling these cookies may result in less targeted advertising.
• Social Media Cookies. These cookies are set by social media services that have been added to the site to enable you to share content with your social media network.  These cookies track your browser across other sites and can be used to build a profile of your interests.  Disabling these cookies may impact the content and messages you see on other websites you visit. 

1. Information from Other Sources

 

We may obtain both personal and non-personal information about you from business partners, contractors, suppliers, and other third parties and add it to other information we have collected.  We, and the third parties we engage, may combine information we collect from you over time, and across the Site, with information obtained from other sources.  This helps us improve the information’s overall accuracy and completeness, and also helps us better tailor our interactions with you.

 

1. Social Media

 

If you interact with us on any social media platform: (a) depending on your social media privacy settings, the personal information that you submit on the social media platform may be read, collected, or used by us as described in this Policy, and (b) where we respond to any interaction with you on social media, your account name/handle may be viewable by any and all members or users of our social media accounts.  Social media platforms operate independently from Simpler Trading and we are not responsible for the personal information that you choose to submit or link on any social media platform.  We encourage you to review the privacy policies and settings of any social media platform with which you interact to help you understand their privacy practices.

 

How We Use Personal Information

 

We (or service providers acting on our behalf) may use the personal information identified above for the following purposes:

 

• Negotiating, entering into, and managing our business relationship and agreements with you, including providing our products, tools, and services, and processing payments from your company.
• Registering you as a member and providing you access to the content and benefits of membership, including our resource tools and online trading chatrooms.
• Enrolling you in, and providing you with, courses for which you have registered.
• Providing and optimizing your experience on our Site and ensuring that our content is presented to you in the most effective manner.
• Communicating with you and responding to your inquiries and communicating regarding our products and services, our agreements with you, and other issues.
• Sending you promotional or informational communications and solicitations, tracking your marketing preferences, engaging in online advertising directed to you, and for our internal marketing purposes.
• Managing customer service issues, including issues relating to the performance of our products/services and customer feedback.
• Developing, updating, and improving our services, customer service, and customer experience, and otherwise improving our knowledge and insights regarding customers.
• Preventing and detecting fraud, financial crime, hacking activities, security breaches, and other unlawful activities in connection with the Site or the purchase or use of our services.
• Enforcing our agreements with your company, complying with our legal or regulatory obligations, and defending or advancing legal claims.
• Notifying you about changes to our Site, services, or material changes to this Policy.
• Providing you with surveys or otherwise soliciting feedback from you.
• Performing other functions as otherwise described to you at the time of collection or to which you otherwise consent.

 

For more information about your options relating to your personal information and your communication preferences, see “Choices About the Collection and Use of Personal Information” below.

Our Marketing Efforts

We may send you direct marketing communications from time to time including news, updates, offers, and other promotions relating to our services and activities. We will only send marketing messages where the law allows us to do so and, in the event that you no longer wish to receive marketing from us, then you can always unsubscribe using the option provided in the footer of the communication you have received or by contacting us using the information below.  We may also engage in online marketing directed to you.

Disclosure of Personal Information

When the information we collect about you is aggregated, anonymized, or otherwise does not identify you, we may use that information for any purpose or share it with third parties, to the extent permitted by applicable law.

 

In addition, we may share your information with the following types of entities:

 

• Business partners, service providers, and third-party vendors necessary for the performance of any contract we enter into with you. For example, our IT providers, secure payment processing providers on the Site, insurance providers, and document storage providers.
• Service providers we use to facilitate our business operations and administration. These third parties have access to your personal information only to perform specific tasks on our behalf and are obliged not to disclose or use it for any other purpose. For example, our service providers include (i) IT and system administration providers, (ii) cloud hosting providers, and (iii) vendors to facilitate payments and payment processing.
• Marketing and advertising vendors that may assist with lead generation, hosting information relating to clients and potential clients, marketing automation, advertisement placement and targeting, and marketing campaigns and communications.
• Analytics vendors in order to understand our Site traffic and usage patterns, optimize our Site, and identify potential new clients.
• Regulatory and governmental authorities, law enforcement agencies, and courts, as necessary to comply with applicable laws and regulations, respond to a subpoena, search warrant, or other lawful request for information, or to otherwise protect our rights.
• Our professional advisors, such as lawyers, accountants, and other similar advisors.
• Buyers or other successors prior to or in the event of a merger, acquisition, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, where the information is among the assets being transferred.
• Other parties for any purpose we disclose at the time you provide the information.

Protection of Personal Information

We use appropriate administrative, technical, and physical measures to protect your personal information from loss, theft, and unauthorized use, disclosure, or modification.  Please be aware that no data transmission over the Internet is 100% secure.  While we strive to protect your personal information, we cannot ensure or warranty the security of any information you transmit to us and you do so at your own risk.

Your Choices About Personal Information

We respect your right to make choices about the ways we collect, use, and disclose your information.  We try to offer you meaningful choices regarding your personal information.  Some choices you have regarding personal information include the following.

• Marketing Emails – As required by applicable laws, you can opt-out of receiving promotional emails from us by clicking the “opt out” link in any such promotional emails and following the instructions provided.

 

• Cookies – Depending on your browser or device, you may have the option to set the browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Each browser and device are different, so we recommend you evaluate the tools and settings available in your browser or device, as well as any available instructions for the same.  Please note that if you disable or delete cookies, you may not be able to access or use certain features of the Site.
• Google Analytics – As discussed above, we use Google Analytics in connection with the Site. If you would like to refrain from having your data collected by Google Analytics, Google has developed an opt-out browser that you can use.  You can find more information on how Google uses information it collects here.

 

• Interest-Based Advertising – To opt-out of personalized or interest-based advertisements, you may be able to adjust the settings on your device. Please go to your device settings and opt-out through the controls provided through Google/Android or iOS, as applicable. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices, has its own instructions on how to prevent the delivery of interest-based advertisements. (We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each mobile platform, not us.). For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.  You can also visit https://optout.aboutads.info to opt out of interest-based advertisements.

 

• Declining to Provide Information – You can choose not to provide us with information we may request through our Site, but that may result in you being unable to use certain features of our Site, request information about our products and services, or initiate other transactions with us.

 

• Do Not Track Mechanisms – Please note that our Site does not honor “Do Not Track” signals, and such signals will not impact the operation of this Site.

 

In addition to the above, you may contact us using the details provided at the end of this Policy with any questions about the choices relating to your personal information.

Links to Third-Party Websites

Our Site may contain links to third-party websites.  Such websites have separate privacy policies that you should review.  We do not control these third-party websites and are not responsible for the content of linked websites or those companies’ data-handling practices.

Rights Afforded to Certain Individuals

1. EU / UK Residents

 

1. Rights Under GDPR

The European Union’s General Data Protection Regulation and the United Kingdom’s version of the same (collectively, the “GDPR”) afford certain rights to individuals in the European Economic Area (“EEA”).  If you are in the EEA, you have the following rights.  Note, however, that not all rights apply in all circumstances.

 

• Right of access: subject to certain exceptions, you have the right of access to your personal information that we hold. If you are requesting access to your data in order to protect the rights of others, we may require you to validate your identity before we can release that information to you.
• Right to rectify your personal information: if you discover that the information, we hold about you is inaccurate or incomplete, you have the right to have this information rectified (i.e., corrected).
• Right to be forgotten: you may ask us to delete information we hold about you in certain circumstances. This right is not absolute and it may not be possible for us to delete the information we hold about you, for example, if we have an ongoing contractual relationship or are required to retain information to comply with our legal obligations.
• Right to restriction of processing: in some cases, you may have the right to have the processing of your personal information restricted. For example, where you contest the accuracy of your personal information, its use may be restricted until the accuracy is verified.
• Right to object to processing: you may object to the processing of your personal information (including profiling) when it is based upon our legitimate interests. You may also object to the processing of your personal information for the purposes of direct marketing and for the purposes of statistical analysis.
• Right to data portability: you have the right to receive, move, copy, or transfer your personal information to another controller when we are processing your personal information based on consent or on a contract and the processing is carried out by automated means.

With regard to the personal information discussed in this Policy, we are typically the “data controller” for such information under the GDPR.  As a result, if you wish to exercise one of the rights discussed above, you may do so by submitting a written request to [insert email address].  This is normally free, unless this process is unduly difficult or is clearly unfounded, repetitive, or excessive, in which case we may charge a reasonable fee or decline to respond.  Once we have received your request, we will review it and contact you within thirty (30) days of receipt of your request, will notify you of any delay in processing your request and, in any event, will respond to the request within three (3) months.  Please note that we may need to request specific information from you to help us confirm your identity.  If you are located in the EEA or UK and have a concern about our processing of your data, you may have the right to make a complaint to the appropriate data protection authority in the EEA or UK. 

 

1. Lawful Basis under GDPR

We will process different types of information under different lawful bases under the GDPR depending on the nature of the information and your relationship with us. The following table describes how we plan to use your personal information and our lawful basis for doing so.  We may process your personal information on more than one basis depending on the specific purpose for which we have collected or are otherwise using your information.

 

Purpose/Activity	Type of Information	Basis of Processing
To enter into and subsequently to manage our business relationship with you, including: ·         Negotiating, entering into, and performing agreements with you ·         Providing you the products you have purchased ·         Managing your membership and providing you access to content pursuant to the same ·         Responding to inquiries and providing customer support and service ·         Managing and processing transactions for our services ·         Notifying you about changes to our website, business terms, or this Policy ·         Communicating with you and responding to your inquiries regarding our products and services, your membership or purchases, and other issues	·         Contact Information ·         Site and Service Information ·         Transactional Information ·         Communications Information	·         Necessary for our legitimate interests (to manage our business relationships and administer our operations including through the keeping of appropriate records) ·         Performance of a contract with you ·         Necessary to comply with legal obligations
To administer and protect our business and Site including: Maintaining, monitoring, and administering the Site, including the online trading chatrooms Maintaining business records for legal purposes and to comply with tax requirements Defending and advancing legal claims Enforcing our rights under any agreements Ensuring effective security for our services and website Conducting website maintenance  Identify and address security risks and unlawful activity	·         Contact Information ·         Site and Service Information ·         Transactional Information ·         Communications Information ·         Device and Usage Information	·         Necessary for our legitimate interests (running our business, facilitating administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise) ·         Necessary to comply with legal obligations
To make decisions about how best to deliver relevant website content and advertisements to you, and otherwise market to you, and to better understand the effectiveness of our marketing efforts	·         Marketing Information ·         Transactional Information ·         Communications Information ·         Device and Usage Information	Necessary for our legitimate interests (better understanding website functionality and how website users navigate and interact with the site)
To advance and promote our business interests including contacting you regarding products, services, or promotions that may be of interest to your company, conducting surveys or soliciting feedback on our services, and updating, developing, and improving our products/services, customer service, and marketing efforts	·         Contact Information ·         Marketing Information ·         Transaction Information ·         Device and Usage Information	Necessary for our legitimate interests (to enhance our services, improve our marketing strategies and develop our business)

 

• Transfers from the EEA, Switzerland, or UK

If we transfer personal information from the EEA, Switzerland, or UK to the United States or any other country, we will implement appropriate legal mechanisms to ensure and adequate level of personal data protection consistent with the GDPR’s requirements.  For example, if the recipient country has not received an Adequacy Decision from the European Commission (such as the United States), we will rely on Standard Contractual Clauses (SCC) that have been approved by the European Commission as the lawful mechanisms for such transfers.  Further, we will enter into appropriate data processing agreements with all non-EU (sub)processors that contain SCCs and define data protection standards to be employed by each (sub)processor.

1. California Residents

If you are a California resident, please refer to our “Privacy Notice for California Residents” [insert hyperlink] for a description of rights available to you under California law.

1. C. Nevada Residents

Under Nevada law, Nevada residents who have purchased services from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law) for monetary consideration to a person for that person to license or sell such information to additional persons.  “Covered information” includes first and last name, address, email address, and phone number, or an identifier that allows a specific person to be contacted either physically or online.  We do not engage in any activities that would qualify as a sale under Nevada law.  

International Transfers

Simpler Trading is headquartered in the United States and, as a result, the information you provide to us may reside on servers or workstations located the United States.  You understand and consent that information you provide may be transferred to the United States.  You also understand that the data protection laws in the United States may be different from those of the country where you reside.  When we transfer personal information to the United States, we will implement appropriate and suitable safeguards to protect such information as may be required by applicable data protection laws.

Children’s Privacy

Our Site is a general audience site and is not directed at, or intended for use by, children under the age of 16 years.  Accordingly, we do not knowingly collect personal information from children under age 16.  Should we discover that a child under the appropriate age provided his or her personal information, we will use that information only to respond to that child and inform him or her that we must have parental consent before receiving such information.

Data Storage and Retention

We will only retain your personal information for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or other mandatory reporting requirements. To determine the appropriate retention period we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, the purposes for which we process it, whether we can achieve those purposes through other means, and the applicable legal requirements.  We also consider any specific limitation periods under applicable law. 

Changes to this Policy

Please note that we may change this Policy from time to time.  If there are changes to our Policy, we will post them here and update the “Last Updated” date at the top of this document. Continued use of this Site after any changes is deemed to be acceptance of those changes.  Accordingly, we encourage you to check the Policy periodically for updates.

How to Contact Us

For questions or more information about our privacy practices, please contact us by e-mail at [email protected]