Privacy notice
Last updated: 2/11/26
This Privacy Notice describes the information collected through this website and any other website or mobile application upon which this Privacy Notice is posted (collectively, the “Site(s)”) and the related products and services we provide, whether online or offline, and how that information is collected, used, and disclosed. The Sites and our products, services, mobile applications, online platforms, and other software upon which this Privacy Notice is posted are referred to as the “Services”. Topstep Brokerage LLC (together with its subsidiaries, “Company”, “we,” “us,” or “our”) and its suppliers may collect or receive the types of information described below as a result of your access to and use of the Services.
This Privacy Notice does not apply to information that we collect about U.S. residents who apply for, use, or otherwise interact with our financial products and services for personal, family, or household purposes. Please refer to our U.S. Consumer Privacy Notice for more information.
Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice.
If you do not agree with this Privacy Notice, do not access or use the Services.
Table of contents
- Changes to this privacy notice
- Information we collect and how we use it
- Other information collected
- Retention of personal information
- Automated processing
- Your choices and access
- Additional information for certain U.S. residents
- Additional information for individuals located in the EEA
- Exercise your rights
- Accuracy and information security
- Access by children
- Third-party websites and services
- International transfers of personal information
- Contact us
1. Changes to this privacy notice
We reserve the right to modify this Privacy Notice at any time. All changes will be effective immediately upon posting the updated Privacy Notice on the Site. By accessing or using the Services after any changes are made, you agree to those changes. Material changes will be clearly posted on the Site or otherwise communicated to you (e.g., via email).
2. Information we collect and how we use and disclose It
Collection. We will collect any and all information that you choose to submit to us through, using, or in connection with the Services, including, without limitation, the types of information described below.
| Categories of Information | Examples and Subcategories | Purposes (defined below) |
|---|---|---|
| Identifiers | Your first and last name, email address, postal address, telephone number, and date of birth.
Usernames, login information (including, for example, passwords). |
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| Protected Classifications Under Applicable Law | Age, sex (including possibly gender, gender identity, gender expression). | |
| Internet or Other Electronic Network Activity | Web browser, IP addresses, MAC Address, log files, login information, cookies, pixels, beacons, other unique online identifiers, and device and user activity information (e.g., search parameters, online activity such as date and time of accessing our websites, website addresses accessed, the length of website visit, and other usage data). | |
| Commercial Information | Amount and types of orders and transactions, Services and products requested or purchased. | |
| Sensitive Personal Information |
Social Security numbers, passports, driver’s licenses, and other government identifications and numbers.
Account log-in credentials. Citizenship or immigration status. Biometric identifiers. |
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| Geolocation Information | Approximate geolocation through IP Address. |
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| Professional or Employment Related Information | Business contact information, job title, entity you represent or work for, business telephone number, business address, business email address. | |
| Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information | Photos and avatars you upload to the Services. | |
| Contact Forms and Requests for Information or Support | The Identifiers you submit, details about the products or services you are interested in, the entity you represent, and the subject matter you are interested in. | |
| Inferences | Preferences, behaviors, characteristics (including, for example, age, gender), and similar information inferred from the above categories of information. | |
| Performance; Trade Data | Disclosed information about your income, account balances, financial transaction history, source of funds, credit history (where self-reported), and risk tolerance.
When you receive, submit, or complete a transaction via the Services, we collect information about the transaction, such as transaction amount, type and nature of the transaction, and time and date of the transaction. |
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| Regulatory | Information gathered and reviewed for your futures account such as your name, occupation, principal occupation or business, estimated annual income and net worth, employment status (including the name of your employer or whether you are self-employed or retired), your estimated liquid net worth (such as cash, securities and other liquid assets), your marital status and the number of your dependents. |
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Purposes We Process Your Information For. In addition to the uses and sharing described above, Company and its suppliers may use and disclose information as described below. We do not use, sell, rent, or otherwise disclose information except as stated in this Privacy Notice and as required or permitted by applicable law.
- Services and Purpose Collected; Communication with You. We will use and share personal information about you and other information for the purpose for which it was collected, for example, to process and communicate with you in connection with your use of the Services (including, for example, your purchases and account activity), your requests for information, User-Generated Content you provide, to administer your account (where applicable) and Company business activities, to provide customer support to users of the Services, and to provide you communications that you request.
- Personalization; Advertising; Analytics. To tailor the content and information that we may send or display to you, to suggest personalized help and instructions, and to otherwise personalize your experience while visiting or using our Services. Additionally, we may collect your information and share it with our third party service providers to understand how our Services are used and to improve the Services (as described further in the “Analytics” section of the Privacy Notice below). Further, we may use your information for us, or our third party service providers, to use that information to target advertisements for goods and services and to display those advertisements on other websites. The information collected may be associated with your personal information. For more information, please see the “Advertising Networks, Personalized Advertising, Remarketing, and Retargeting” section of the Privacy Notice below.
- Promotional Communications. Company may, to the extent permitted by applicable law and in accordance with your preferences, use information to send you promotional communications about Company and our products and services. Company will obtain your prior consent for such promotional communications where required to do so under applicable law. In order to provide you with a personalized experience, these communications may be tailored to your preferences based on, for example, inferences we make using your visits to the Services or the links you click on in Company emails. Please note that pixel tags, cookies and other online trackers may be used within emails to track your interactions with those websites and when emails are opened. You may opt out of receiving promotional communications from us at any time by following the unsubscribe instructions contained in the applicable email or by contacting us using the contact information provided below under “Contact Us.” Specifically with regard to text messaging, if you opt in to receiving text messages (SMS and MMS) on the Services when prompted, Company may send you autodialed and other text messages at the telephone number you provide relating to your use of the Services. Consenting to receiving text messages is not required to buy goods or services or to otherwise do business with us. Message and data rates may apply. See our Terms of Use for more information. Note that, even if you opt out of receiving promotional communications from Company, you may still receive transactional communications from us with respect to your use of the Services.
- Disclosing Collected Information.
- To our Affiliates, Subsidiaries, and Related Entities: Based on how you use the Services and the information that you provide to or request from us, we may disclose your name, contact information, and related information with our affiliated companies who have products or services that we think may be of interest to you. By providing us information and using the Service, you hereby direct us to disclose your information to our affiliates, subsidiaries and other related entities. Our affiliated companies may contact you directly with respect to such products and services, provided that if applicable law requires, your prior consent will be obtained. You may opt out of receiving communications from any such affiliated company pursuant to that affiliate’s own policies. You may opt out of receiving non-transactional communications from us by contacting us using the information below under “Contact Us.”
- To Our Third-Party Suppliers and Service Providers: We will disclose information to our and our affiliates’ respective suppliers, vendors, and service providers as necessary for us to provide the Services and our products and services to you and to engage in the use and sharing of information as permitted by this Privacy Notice and applicable law. These third parties include, without limitation, our website management and hosting suppliers, fraud detection and other security providers, customer support providers, those handling the processing and delivery of mailings, cloud storage providers, marketing and advertising partners and service providers, website analytics providers, payment processors (if and as applicable), product installers, and email service suppliers. Our service providers are authorized to and may use and disclose information as necessary for them to provide the applicable products and services to us and as provided by their own privacy policies and our agreements with those third parties.
- Evaluation and Improvement. We may use and disclose information to analyze, develop, and improve the content, materials, products, and services that we provide; to inform marketing and communication plans and strategies; to understand user demographics and preferences; to analyze the effectiveness of the Services; and to evaluate user needs and customize Services content and the user experience. To better understand how users access and use our Services, both on an aggregated an individualized basis, including monitoring, evaluating, and analyzing which features and portions of the Services are most popular; for troubleshooting, for statistical purposes, including, for example, identifying geographic regions of visitors to our Services; evaluating frequently asked questions from visitors; and for other statistical purposes.
- Brokerages, FCMs & other financial institutions. In order to provide the Services, we will obtain information from, and provide information to, the applicable brokerage or Futures Clearing Merchants (FCMs) with which you engage. By disclosing your information, including, without limitation, personal information about you, with us and setting up an account for the Services, you hereby direct us to interact with and disclose your information, including, without limitation, personal information about you, to the applicable brokerages and FCMs with which you engage. We encourage you to review the privacy policy of any brokerage or FCM that you use or visit in connection with the Services, as those platforms’ respective privacy policies will govern their collection, use, and disclosure of information they collect from you. We cannot control any policies or terms of such entity. As a result, we are not responsible for any use or disclosure of your information or content by such brokerages and FCMs, which you use at your own risk.
- Risk Tracking. We will monitor your use of the Services and patterns in your use of the Services to determine if you are engaged in activity that is illegal, fraudulent, in violation of any agreement you have with us or our Terms of Use, or that introduces, causes or could cause risk for other users, our customers, partners, or Company.
- Quality Assurance. In order to perform quality assurance and to continuously improve our customers’ experience, to assist with fraud identification, and to assist our customer relationship representatives (for example, through representatives in our call center), we use tools to monitor and record certain user experience information, including, without limitation, audio of customer service calls and information resulting from such calls.
- De-Identified and Aggregated Data. We may de-identify and/or aggregate personal information and User-Generated Content, and aggregate other information, and use and disclose that aggregate and/or de-identified data for our business purposes, in each case to the extent permitted by applicable law. To the extent we create de-identified and/or aggregate personal information, we take reasonable measures designed to maintain such information in de-identified and/or aggregate form. Once de-identified or aggregated, we will not attempt to re-identify the data (other than to confirm our de-identification and aggregation processes worked).
- Lawful Processes; Protection of Company. We may use and share information in accordance with and in response to regulatory authorities, courts with competent jurisdiction, valid law enforcement requests or inquiries, governmental agency or regulatory (or self-regulatory) organization requests or inquiries, emergency services, direct or indirect investigations, and other necessary third parties for legal, protection, security, and safety purposes (e.g., to comply with laws or regulations, to respond to subpoenas and legal processes, to perform credit checks, to protect the safety of our employees, agents, and customers, or any other person). We also may use and share information as permitted by applicable law (for example, cooperating on and filing suspicious activity reports and responding directly or indirectly to requests or inquires made by clearinghouses, FCMs and other financial institutions). We may use information and share it with third parties if we believe doing so is necessary or appropriate to protect our rights or the rights of others, including to enforce our agreements, policies, and terms, to bring legal action, to protect our operations and assets, or to pursue remedies or limit damages that we may sustain.
- Business Transactions. If Company undergoes a change in control, acquisition, merger, reorganization, asset sale (in whole or in part), or similar transaction, we may transfer, sell, share, or otherwise disclose information to the subsequent owner(s) or successor(s) of those transactions. We may also disclose information in connection with the evaluation of those transactions. Those owner(s), successor(s), and other recipients will be bound by this Privacy Notice as it applies to the information disclosed. Also, if Company or any of its assets are acquired or if Company goes out of business, enters bankruptcy, or goes through some other change in control or reorganization, information may be one of the assets transferred to or acquired by a third party.
- With Your Consent. With your consent, we may use and share personal information and other information in ways not specifically described in this Privacy Notice.
| Categories of Information | Categories of Third Parties Disclosed to | Purposes for Disclosure |
|---|---|---|
| Identifiers |
Affiliates, Subsidiaries, and Related Entities.
Subsequent owner(s), successor(s), or assignee(s) of Company. Third Party Service Providers, which include, for example, payment processing companies, data analytics and advertising providers, fraud prevention providers, cloud storage providers, IT service providers, delivery partners, and marketing companies. Brokerages, FCMs, Exchanges & Clearinghouses, other financial institutions. Law Enforcement & Regulatory Authorities. |
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| Protected Classifications Under Applicable Law | ||
| Internet or Other Electronic Network Activity | ||
| Commercial Information | ||
| Sensitive Personal Information | Subsequent owner(s), successor(s), or assignee(s) of Company.
Third Party Service Providers, which include, for example, payment processing companies, data analytics and advertising providers, fraud prevention providers, cloud storage providers, IT service providers, delivery partners, and marketing companies. Brokerages, FCMs, Exchanges & Clearinghouses, other financial institutions. Law Enforcement & Regulatory and Self-regulatory Authorities. |
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| Geolocation Information | Affiliates, Subsidiaries, and Related Entities.
Subsequent owner(s), successor(s), or assignee(s) of Company. Third Party Service Providers, which include, for example, payment processing companies, data analytics and advertising providers, fraud prevention providers, cloud storage providers, IT service providers, delivery partners, and marketing companies. Brokerages, FCMs, Exchanges & Clearinghouses, other financial institutions. Law Enforcement & Regulatory and Self-regulatory Authorities. |
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| Professional or Employment Related Information | ||
| Audio, Electronic, Visual, Thermal, Olfactory, or Similar Information | ||
| Contact Forms and Requests for Information or Support | ||
| Inferences | ||
| Performance; Trade Data |
User-Generated Content. You are responsible for any data, information, images, messages, documents, and other content that you enter, submit, create, post, upload, transmit, or otherwise provide through or using the Services, including by providing feedback, participating in forums or discussion boards, by uploading or providing photographs, by submitting product reviews or testimonials, by commenting on blog posts, or by populating a user account or profile (where such options are made available to you). “User-Generated Content” means all data, feedback, information, images, messages, documents, and other content that is entered into, submitted to, posted on, uploaded to, transmitted, streamed, created, or displayed using, or otherwise provided via or using the Services by you or on your behalf. All User-Generated Content is provided at your own risk. We cannot guarantee that User-Generated Content you provide will not be viewed by unauthorized persons. You understand that, even after removal, copies of User-Generated Content you have provided may remain viewable in cached and archived pages and may have been copied or stored by Internet archives and other Service users. We will make User-Generated Content available, including publicly available, to other Service users and to the public, as applicable and at its sole discretion, and will use and disclose User-Generated Content for the purpose for which it was provided as indicated at the point of collection. See our Terms of Use for more information.
3. Other information collected
As you navigate and use the Services, certain information can be passively collected using various technologies. We passively collect a variety of types of information in a variety of ways, including as described below.
User Activity. We collect information on how the Services are used, for example, the features you use, the links that you click on, your search parameters, data reflecting transactions that have taken place using the Services, how you interact with other users, performance statistics, and other usage data. We collect information that your browser sends whenever you visit our Services (“Log Data”). This Log Data may include information such as your computer’s Internet Protocol (“IP”) address, browser type, browser version, the pages of our website that you visit, the time and date of your visit, the time spent on those pages and other statistics.
IP Addresses and Related Data. The servers used to operate and provide the Services may collect, and our third-party service providers may collect, data pertaining to you and the equipment, software, and communication methods you use to access the Internet and the Services, including IP addresses assigned to the computers and other devices from where you access the Internet, your Internet service provider (ISP), device ID numbers and unique identifiers, your media access control (MAC) address, your operating system, your device’s screen resolution, your web browser type, the pages you access on the Services, the websites you access before and after visiting the Services, the length of time you spend on the Services, date and time stamps, clickstream data, your approximate geographic location, performance statistics, and usage data. Company may use this information to administer the Services and their servers, to generate statistical information, to monitor and analyze Service traffic and usage patterns, to monitor and help prevent fraud, to investigate complaints and violations of our policies, and to improve the Services.
We may combine this information with other information (including personal information) and information obtained from third parties for security reasons and to protect our rights or the rights of others. The suppliers that we use to provide the Services may collect information about your visits to the Services and other websites. Some of this information may be collected using cookies and similar tracking technologies as explained below under “Cookies and Tracking Technologies.”
Social Media. Certain features of the Services allow you to initiate interactions between the Services and third party services or platforms, such as social networks (“Social Features”). Social Features include features that allow you to access our pages on third party platforms, and from there “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use information about you. If you use Social Features, information you post or make accessible may be publicly displayed by the third party service. Both we and the third party may have access to information about you and your use of both the Services and the third party service for more information, see the section below, Third Party Websites and Services.
Cookies and Tracking Technologies. The Services automatically use cookies and tracking technologies to track your use of the Services in order to facilitate and enhance the user experience on the Services, to learn and track how you access and use the Services, including when and how users visit the Services and how popular particular Service pages are and aren’t, to provide you with customized advertising, and for other purposes as described herein.
Most browsers accept cookies and other tracking technologies automatically, but you may be able to control the way in which your devices permit the use of tracking technologies. If you so choose, you may block or delete our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including certain features and general functionality, to work incorrectly. Changing your cookie preferences in one browser will not necessarily carry over to other browsers, so you may need to adjust your preferences each time you get a new device, install a new browser, upgrade an existing browser, or alter or delete a browser’s cookie file. If you have questions regarding the specific information about you that we process or retain, as well as your choices regarding our collection and use practices, please contact us using the information listed below.
Cookies are small pieces of information that are stored on your device’s hard drive by your web browser. The Services may use both cookies that we implement (sometimes referred to as first-party cookies) and cookies implemented by our suppliers and other third parties (sometimes referred to as third-party cookies). The Services may use both cookies that we implement, and cookies implemented by our suppliers and other third parties. “First-party” cookies allow your browser to talk to the actual website that you are visiting, whereas “third-party” cookies allow your browser to talk to third-party websites, such as the source of an ad that appears on the website you are visiting or a third-party analytics provider. Our suppliers may use cookies and tracking technologies to track Service users across the Internet to understand how you get to the Services and for the analytics purposes disclosed in this Privacy Notice. A cookie can either be a “session” cookie or a “persistent” cookie. Session cookies exist only for so long as you are visiting the applicable website. Session cookies are typically deleted or removed when you exit or quit your browser application. Persistent cookies exist for a set period of time.
The types of information collected by a cookie and the purposes for which that information is used will depend on the type of cookie. By way of illustration, the types of cookies used, the types of information collected by those cookies, and the purposes for which that information are used are described below.
- Necessary cookies are required for the operation of the Services.
- Functional cookies offer enhanced functionality when accessing or using the Services.
- Performance & analytical cookies assess the performance of the Services and enable us to personalize content and remember your preferences.
- Advertising or targeted cookies are used to make the Services and its content more relevant to your interests (this is sometimes called “behavioral” or “targeted” advertising and is further discussed above) and to limit the number of times you see an advertisement and to help measure the effectiveness of advertising campaigns.
For more information about cookies, including about advertising cookies and your choices regarding cookies, we suggest you visit the following websites: https://www.consumer.ftc.gov/articles/0042-online-tracking; http://www.allaboutcookies.org; http://www.youronlinechoices.com; and http://www.youronlinechoices.eu.
Analytics Tools & Providers. The Services use third-party analytics tools (e.g., Google Analytics) to collect and process data about your use of the Services. Our analytics providers may set and read cookies to collect this data, and your web browser will automatically send data collected by those cookies to our analytics providers. Our analytics providers use this data to provide us with reports that we will use to improve the Services’ structure and content.
For example, we utilize Google Analytics and other analytical tools offered by Google. For more information on how Google uses this data, visit Google’s page on How Google uses data when you use websites or apps that use Google Services. To prevent this data from being used by Google Analytics, follow the instructions to download and install the Google Analytics Opt-out Browser Add-on for each browser you use. Using the Google Analytics Opt-out Browser Add-on will not prevent us from using other analytics tools and will not prevent data from being sent to the Service itself or to Google.
Advertising networks, Personalized Advertising, Remarketing & Retargeting. We may use or participate in advertising networks and related advertising services that are managed and provided by third-party advertising servers, advertising agencies, technology vendors, and research firms, including, but not limited to, Google Ads, advertising services provided by Meta (sometimes referred to the Meta “tracking pixel”), and advertising services provided by TikTok (sometimes referred to as TikTok Pixels).
Advertising networks often gather data about consumers who view advertisements to make inferences about a consumer’s interests and preferences, which enables their computers to deliver advertisements directly targeted to the consumer’s specific interests. This practice is often referred to as “online behavioral advertising.” For example, a third-party advertising network might collect the type of web browser you use, the type of computer operating system you use, the domain name of a website you visit, whether or not you visit specific pages of the Services and other websites, the location of your Internet service provider, the date and time of a visit to a website, and other interactions between you and a website.
Through Google Ads, Google uses your Internet searches, cookies, and similar identifiers (e.g., pixel tags) to collect information about your visits to the Service and your interaction with our products and services to generate targeted advertisements to you on other websites that you visit across the Internet. We may also enable and implement Google Analytics Advertising Features on the Services. To opt out of remarketing advertising provided through Google, to customize your ad preferences, or to limit Google’s collection or use this information, visit Google’s Safety Center and Google’s Ad Settings and follow Google’s personalized ad opt-out instructionsGoogle’s personalized ad opt-out instructions.
For certain Meta advertising services, Meta Ireland is a Joint Controller (as defined in the GDPR) and that information required under the GDPR related to such processing can be found at https://www.facebook.com/about/privacy. We work with Meta and use their advertising services to measure and improve our ads and marketing efforts, as well as to display more relevant advertising to you. For further information on how Meta Ireland processes your personal information, including the legal basis, and the ways to exercise your rights, please visit https://www.facebook.com/about/privacy.
To change your preferences with respect to certain online ads and to obtain more information about third-party ad networks and online behavioral advertising, please visit the National Advertising Initiative Consumer opt-out page. Please remember that changing your settings with individual web browsers or ad networks will not necessarily carry over to other browsers or ad networks. As a result, depending on the opt-outs you request, you may still see our ads from time to time. Your device may also include a feature (“Limit Ad Tracking” on iOS or “Opt Out of Interest-Based Ads” on Android) that allows you to opt out of having certain information collected through apps used for behavioral advertising purposes
Do-Not-Track Signals & Global Privacy Control. Due to the automatic collection of data using cookies as described above, we do not honor “do not track” requests. For this reason, your selection of the “Do Not Track” option provided by your browser may not have any effect on our collection of information using cookies and tracking technologies. However, residents of certain U.S. states may opt out by broadcasting an Opt-Out Preference Signal under applicable law, including the Global Privacy Control (GPC), depending on which browsers and/or browser extensions you use that may support such a signal. To look at extensions and browsers supporting the GPC browser signal, visit here: https://globalprivacycontrol.org/. Note that if you choose to use the GPC signal, you will need to turn it on for each supported browser or browser extension you use.
Embedded Content. The Services may incorporate content, including feeds, scripts embedded in the Services’ code, and visible content (e.g., videos), provided by third parties. In some cases, those third parties collect data about how you interact with their content. Our Services may use YouTube to make content in video format available to you. By accessing a part of the Services where videos are available, watching an embedded video, or otherwise interacting with any content made available through YouTube, you signify your agreement with YouTube’s terms and conditions. YouTube collects and otherwise has access to usage data (e.g., what videos you accessed and watched) through videos embedded in the Services as further described in YouTube’s Privacy Notice. YouTube adheres to Google’s privacy policies and principles, part of which allow you to control certain privacy settings and which data are collected. For more information, please visit https://www.youtube.com/howyoutubeworks/user-settings/privacy/.
Information that We Obtain from Third-Party Sources. We may obtain data about users of the Services from various third-party companies and public sources, whether offline or online (e.g., marketing companies, analytics consultants, publicly available social media profiles, other public sources of information), and we may combine that data with information we collect. This enhances our existing information about our users and customers and improves our ability to contact you and our marketing’s relevancy.
Manage Cookie Settings. In certain jurisdictions, you may also have the ability to adjust or revoke your cookie preferences at any time using the button below:
4. Retention of personal information
We will retain personal information for as long as it’s needed to fulfill the purposes outlined in this Privacy Notice and our Terms unless a longer retention period is required or permitted by law (e.g., tax, accounting, or other legal requirements).
When we have no ongoing legitimate business need to process personal information, we will either delete or anonymize it; if that is not possible (e.g., because personal information has been stored in back-up archives), we will take measures designed to securely store personal information and isolate it from any further processing until deletion is possible.
5. Automated processing
Other than as may be described in this Privacy Notice, you will not be subject to decisions based on automated information processing without your prior consent.
6. Your choices and access
Depending on the laws applicable to Company’s processing of personal information about you and the location in which you reside, you may have the ability to exercise the rights listed below and in this section of the Privacy Notice. Subject to foregoing, in addition to all application limitations, exemptions, or exceptions—regarding our collection and use of personal information about you—these rights may include, to the extent applicable, the right to:
- Right to Confirm: To confirm whether we are processing personal information about you.
- Right to Know: To request that a business that collects personal information about them to disclose (1) the categories of personal information collected, disclosed, sold and/or shared; (2) the categories of sources from which the personal information was collected; (3) the business or commercial purpose for collecting, selling, and/or sharing personal information; (4) the categories of third parties with whom we disclosed, sold, and/or shared personal information; and (5) the specific pieces of personal information we have collected about you.
- Right to Data Portability: To receive all such personal information about you from Company in a structured, commonly used and machine-readable format, and also to require us to transmit it to another entity where this is technically feasible.
- Right to Deletion: To request the deletion of personal information that we have collected about you.
- Right to Correction: To request the correction of personal information that we collected about you.
- Right to Lodge a Complaint: To lodge a complaint with a government regulator (e.g., your state attorney general) or supervisory authority, in particular in your country of residence, if you consider that the collection and use of personal information about you violates this Privacy Notice or applicable law.
To exercise these rights, please see the “Exercise Your Rights” section of the Privacy Notice below. Additionally, if you have any concerns, complaints, or other issues with regard to our collection, use or other processing of personal information, please contact us via the means set forth under the “Contact Us” section of the Privacy Notice below.
7. Additional information for certain U.S. residents
Certain U.S. states require additional disclosures and provide users residing in such U.S. states with additional choices and rights. This section of the Privacy Notice only applies to individuals located in such U.S. states and where such U.S. state data protection laws apply to Company’s processing of personal information about you.
Sources. Consistent with the Privacy Notice above, we collect certain categories of personal information directly from you and, in some circumstances, third parties. The categories of sources that we collect personal information from includes the following:
- Our third party service providers;
- Brokerages, FCMs, Exchanges & Clearinghouses;
- Affiliated, subsidiaries, and related companies;
- Third party websites and mobile applications (e.g., websites that share information with us or our advertising partners);
- Social media companies;
- Our Services; and
- Your communications with us.
Sensitive Personal Information. We only use and disclose sensitive personal information for the purposes permitted under applicable law, in accordance with the disclosures under the “Information We Collect and How We Use and Disclose It” above.
Rights. Applicable laws in your jurisdiction may grant you certain rights—subject to all applicable limitations, exemptions, or exceptions—regarding our collection and use of personal information. In addition to those rights set forth in the “Your Choices and Access” section of the Privacy Notice above, these rights may include, to the extent applicable and to the extent granted under applicable law:
- The right to opt-out of targeted advertising and the sharing of personal information that is shared for cross-contextual behavioral advertising purposes;
- The right to opt-out of the sale of personal information about you;
- The right to appeal; and
- The right to not be discriminated against due to your exercise of your rights under applicable law. We do not discriminate against users for exercising the rights granted to them under applicable law and that are applicable to our processing of personal information about you.
We do not use personal information about you to profile you via purely automated means in furtherance of decisions that produce legal or significantly similar effects (as may be defined under applicable law).
The above rights are only exercisable by you where the applicable law grants you the right being exerted and where no exception or exemption under applicable law applies. You may also have a registered agent (if and only as permitted under applicable law) that you authorize to act on your behalf. If you have a registered agent act on your behalf, we have the right to authenticate such agent’s authority to act. To exercise the rights described herein (only to the extent applicable), you may submit a verifiable request to us by through the methods set forth under the “Exercise Your Rights” section below.
Selling and Sharing. We do not sell your personal information as the concept of “selling” is traditionally understood as being the exchange of something for money. However, we share your personal information with third parties for the purpose of cross-contextual behavioral advertising purposes (e.g., targeted advertising). U.S. state data protection laws may hold such disclosures and sharing to be considered “selling” or “sharing”. Therefore, you have the right to opt out of such activities. In the preceding 12 months, we have sold or shared the following categories of personal information with the following categories of third parties and for the following purposes:
| Category of Personal Information Sold or Shared | Category of Third-Party Recipient | Purpose |
|---|---|---|
| Identifiers | Analytics, marketing, advertising, and remarketing partners and service providers |
Analytical and targeted advertising purposes (including, without limitation, cross-contextual behavioral advertising).
Specifically, to target advertisements for goods and services and to display those advertisements on other websites. |
| Internet or other electronic network activity information | Analytics, marketing, advertising, and remarketing partners and service providers |
Analytical and targeted advertising purposes (including, without limitation, cross-contextual behavioral advertising).
Specifically, to target advertisements for goods and services and to display those advertisements on other websites. |
You have the right to opt out of the selling or sharing of your personal information as described herein. You may exercise this right to opt out by utilizing the Global Privacy Control as mentioned in the “Do-Not-Track Signals & Global Privacy Control” section above, changing your cookie settings via the Manage Cookie Preferences button above, or by clicking the “Your Privacy Choices” option in the footer of the website and changing your Cookie Settings as described on that webpage. If you have any questions, concerns, or would like more information on our ability to opt out, you can contact us by emailing: [email protected].
We do not knowingly sell or share for cross-contextual behavioral advertising purposes, the personal information of anyone under the age of 16 years old. Similarly, we do not sell your sensitive personal information nor do we share your sensitive personal information for purposes of cross-contextual behavioral advertising.
8. Additional information for individuals located in the EEA
This section of the Privacy Notice applies to residents of countries or jurisdictions located in the EEA, including, without limitation, the European Union and the United Kingdom.
Legal Bases We Rely on When Processing Personal Information. To the extent the European Union’s General Data Protection Regulation or other similar law applies to you (including, without limitation, those located in the United Kingdom) and is applicable to Company, we process personal information about you for the purposes set forth in this Privacy Notice under the following legal bases (as applicable):
- Our Contract With You: Our processing is necessary to perform our obligations under a contract with you or to perform steps requested by you prior to entering into a contract with you: (e.g., to verify the information you have provided to us).
- Our Legitimate Interests: Our processing is necessary for our legitimate interests, including to protect the security of our Services; to protect the health and safety of you or others; to establish, protect and defend our legal rights and interests; to prevent fraud and verify identity and authorization of clients; to understand and analyze usage trends; and to improve our products and services. Additionally, we have a legitimate interest in promoting our operations and goals as an organization and sending marketing communications for that purpose.
- Legal Compliance: Where our processing is required to comply with applicable law (for example, to maintain your payment transaction history for tax reporting purposes) e.g., in response to subpoenas, court orders and other lawful requests by regulators, courts and law enforcement agencies, or related to national security requests.
- Your Consent: When we have your express consent as defined by applicable law.
Rights. To the extent the European Union’s General Data Protection Regulation or other law granting particular rights to data subjects applies to you (including, without limitation, those located in the United Kingdom) and subject to all applicable exceptions and exemptions granted under such applicable laws, you may have the following rights with regard to our processing of personal information about you in addition to those rights set forth in the “Your Choices and Access” section of the Privacy Notice above:
- Right to Restrict Personal Information Use and Right to Object: You may have the right to restrict our use of your personal information where (i) you contest the accuracy of the personal information; (ii) the use is unlawful but you do not want us to erase the personal information; (iii) we no longer need the personal information for the relevant purposes, but you require it for the establishment, exercise or defense of legal claims; or (iv) you have objected to our personal information use justified on our legitimate interests pending verification as to whether Company has compelling interests to continue the relevant personal information use.
- Right to Withdraw Consent: In the event personal information about you is processed on the basis of your consent, you have the right to withdraw consent at any time with effect for the future.
Please see the “Exercise Your Rights” section below for information about how to make a request.
9. Exercise your rights
If this Privacy Notice expressly stated above that you have certain rights, or applicable law grants you certain rights as it relates to the Services and information, we collect about you, you may exercise any of these rights by contacting us using the information provided below. You may submit a request to us by:
Calling: 888-407-1611
Emailing: [email protected]
Completing: Data Subject Rights Request Form
Additionally, you may have the right to appeal our decision regarding a request related to these rights by contacting us using the information provided below. If the appeal is denied, you may submit a complaint to the applicable government regulator or authority in the jurisdiction in which you are located (for example, the state Attorney General in the state in which you reside if you are a US resident).
When you submit a request or an appeal, we will limit our collection of information about you to only what is necessary to securely fulfil your request or process your appeal. Making a request or appeal does not require you to create an account with us.
To verify certain requests, for example, requests to know, delete, or correct, we may need to collect additional information to verify your identity and the request, such as your email address, government issued ID or date of birth, before providing a substantive response to the request.
Some jurisdictions, depending on your location, permit you to authorize an agent to make requests on your behalf to exercise your rights. If you have a registered agent to act on your behalf, we have the right to authenticate such agent’s authority to act.
10. Accuracy and information security
Personal information you provide to us should be relevant to the purposes for which it is to be used, and, to the extent necessary for those purposes should be accurate, complete, and up to date.
We have implemented reasonable and appropriate administrative, technical, physical, and organizational security measures designed to help protect against the unauthorized access, unauthorized disclosure, loss, theft, misuse, and alteration of information under our control. However, Company does not and cannot guarantee that unauthorized access, unauthorized disclosure, loss, theft, misuse, and alteration of information will not occur. We do not publish all of our security measures online because this may reduce the effectiveness of our security measures. The storage and communication of information can never be completely secure.
If you become aware of any breach of the Services’ security or of this Privacy Notice, please notify us at [email protected] immediately.
11. Access by children
The Services are not directed at children under 18 years of age. Company does not knowingly collect or use information from children under 18 through the Services. If a parent or legal guardian becomes aware that a child under the age of 18 has provided information to us through the Services, the parent or legal guardian should contact us using the information below under “Contact Us.” and we will use commercially reasonable efforts to delete that information.
12. Third-party websites and services
The Services may link to, or be linked to, websites, applications, or services not maintained or controlled by Company. Company is not responsible for the privacy policies or practices of any third parties or any third-party websites, applications, or services. This Privacy Notice does not apply to any third-party websites, applications, or services or to any personal or other information that you may provide to third parties. You should read the privacy policy for each website, application, and service that you visit or use.
13. International transfers of personal information
Due to the fact that Company’s business is international, personal information about you and other information may be transferred to, stored in, and processed in any country where our or our suppliers’ servers, databases, or facilities are located or operated. By accessing, receiving, or using the Services or by providing consent to us (where consent is required by applicable law), you specifically acknowledge and agree that information will be transferred outside of the country from which you access the Services (including, for example, to the United States) and that such countries’ data protection and related laws, regulations, and rules may be different than, and may not be as protective as, those of the jurisdiction from where you access the Services. Your use of or access to the Services constitutes your consent to such transfers.
Additionally, where required by applicable law, we have ensured that personal information about you included in such transfers is adequately protected through the use of contractual clauses or other adequate measures allowed or required under such applicable laws for example, by signing relevant EU standard contractual clauses as approved by the European Commission (the form for these clauses can be found here). Subject to applicable law, you have the right to obtain details about the mechanism under which personal information about you is transferred cross-border. For more information about these transfer mechanisms, please contact us as set out in the “Contact Us.” section below.
14. Contact us
If you have any questions or concerns regarding this Privacy Notice, contact us by email at [email protected] or by telephone at 888-407-1611.