Privacy Policy Statement

Updated 5/24/18

TradingMarkets is committed to protecting the private sensitive information of our customers. We have revised our Privacy Policy to reflect our commitment, and we strongly urge our customers to take some time to review the new version below.

This privacy notice provides you with details of how we collect and process your personal data through your use of our site https://tradingmarkets.com

By providing us with your data, you warrant to us that you are over 16 years of age.

The Connors Group, Inc. is the data controller and we are responsible for your personal data (referred to as “we”, “us” or “our” in this privacy notice).

Our full details are:

Full name of legal entity: The Connors Group, Inc.
Name or title of Data Protection Officer: Laurence A. Connors
Email address: info@cg3.com
Postal address: 185 Hudson St., Suite 2500, Jersey City, NJ 07311
Telephone number: 1-973-494-7311 ext. 1
Details of our Representative: Laurence A. Connors

It is very important that the information we hold about you is accurate and up to date. Please let us know if at any time your personal information changes by emailing us at info@cg3.com.

1. Information Collection

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Registration and Billing
In order to use some of our services, we ask our customers to give us contact information (name, address and phone number). We use this information to contact customers about services or products that may interest them. We also ask our customers to give us their e-mail addresses and credit card information for certain services. We DO NOT distribute e-mail addresses or phone numbers outside of TradingMarkets, its parent, subsidiaries, affiliates and strategic business partners. We DO NOT disclose credit card information to any entity other than credit card processing companies that assist us in billing customers for goods and services. Our lawful ground for this processing is the performance of a contract between you and us and/or taking steps at your request to enter into such a contract.

Cookies
A cookie is a piece of data stored on the user’s computer tied to information about the user. Usage of a cookie is in no way linked to any personally identifiable information while on our site. We use both session ID cookies and persistent cookies. For the session ID cookie, once users close the browser, the cookie simply terminates. A persistent cookie is a small text file stored on the user’s hard drive for an extended period of time. Users can set up their web browser to inform them when cookies are set or to prevent cookies from being set. If users reject cookies, they may still use our website, but will be limited in using some areas of our website. We use cookies to store our customers user name and password so that they do not have to input these items every time they visit our website. We also use cookies to track our customers’ preferences, such as services or products previously purchased, so that we can provide a better customized service when our customers return to our website. See the Profile section. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Log Files
Like most standard Web site servers we use log files. This includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, platform type, date/time stamp, and number of clicks to analyze trends, administer the site, track user’s movement in the aggregate, and gather broad demographic information for aggregate use. IP addresses, etc. are not linked to our customers’ contact or Sensitive Information. Our lawful ground for this processing is our legitimate interests which in this case are to enable us to properly administer our website and our business.

Personal Data of Children
We do not knowingly collect or solicit Personal Data from anyone under the age of 16. If you are under 16, please do not attempt to register for the Sites or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 16, we will delete that information as quickly as possible. If you believe that a child under 16 may have provided us Personal Data, please contact us at info@cg3.com.

2. Sensitive Data

We do not collect any Sensitive Data about you. Sensitive data refers to data that includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data. We do not collect any information about criminal convictions and offenses.

Where we are required to collect personal data by law, or under the terms of the contract between us and you do not provide us with that data when requested, we may not be able to perform the contract (for example, to deliver goods or services to you). If you don’t provide us with the requested data, we may have to cancel a product or service you have ordered but if we do, we will notify you at the time.

We will only use your personal data for a purpose it was collected for or a reasonably compatible purpose if necessary. For more information on this please email us at info@cg3.com. In case we need to use your details for an unrelated new purpose we will let you know and explain the legal grounds for processing.

We may process your personal data without your knowledge or consent where this is required or permitted by law.

We do not carry out automated decision making or any type of automated profiling.

3. Information Use

Our lawful ground of processing your personal data to send you marketing communications is either your consent or our legitimate interests (namely to grow our business).

Information Use
We provide information about trading. Since our customers often have widely differing uses for our products and services, our strongly held belief and experience is that the more we know about our customers, the more value we can offer them. We use the information our customers provide during registration to offer them personalized collection, filtering, and delivery of information (such as strategies and articles) that is of the greatest interest and value to them.

Third Party Advertising
The ads appearing on our website are delivered to our customers by our Web advertising partners. Information about our customers’ visit to this site, such as number of times they have viewed an ad (but not user name, address or other contact information), is used to serve ads to users on our website. This privacy statement covers the use of cookies by TradingMarkets
only and does not cover the use of cookies by any advertisers.

4. Communications from the Site

Special Offers and Updates
We send all new members a welcoming e-mail to verify password and username. Established members will occasionally receive information on products, services and special deals. Out of respect for the privacy of our users we present the option to not receive these types of communications in these e-mails.

Newsletters
If a user wishes to subscribe to our newsletters, we ask for contact information such as name and e-mail address. Out of respect for our users privacy we provide a way to opt-out of these communications.

Service Announcements
On rare occasions it is necessary to send out a strictly service related announcement. For instance, if our service is temporarily suspended for maintenance we might send users an e-mail. Generally, users may not opt-out of these communications, though they can deactivate their account. However, these communications are not promotional in nature.

Customer Service
We communicate with users on a regular basis to provide requested services and in regards to issues relating to their account we reply via e-mail or phone, in accordance with the users wishes.

5. Sharing

Legal Disclaimer
Though we make every effort to preserve customer privacy, we may need to disclose personal information when required by law wherein we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process served on our website.

Sharing With Third Parties
We do NOT share our customers’ e-mail addresses with third parties, except for when required by law (see legal disclaimer). In order to present our customers with potentially interesting opportunities, we do occasionally share information from certain third parties with you. We believe that our customers will benefit from these arrangements, but out of respect of our clients’ privacy, we will remove such information from disclosure upon request (via e-mail to support@tradingmarkets.com) by our customers.

Third Party Intermediaries
We use an outside shipping company to ship orders, and a credit card processing company to bill users for goods and services. These companies do not retain, share, store or use personally identifiable information for any secondary purposes.

Choice/Opt-out
Our customers are given the opportunity to ‘opt-out’ of having their information used for purposes not directly related to our site at the point where we ask for information. Customers who no longer wish to receive our newsletters and promotional communications via e-mail may opt-out of receiving these communications by clicking on the link provided in the e-mail or by sending us an e-mail us at support@tradingmarkets.com.

Tell-A-Friend
If a customer elects to use our referral service for informing a friend about our site or forwards a TradingMarkets’ commentary to a friend, we ask for the friend’s name and e-mail address. TradingMarkets may send the friend a one-time e-mail inviting them to visit the site. TradingMarkets stores this information for the sole purpose of sending this one-time e-mail and tracking the success of our referral program. The friend may contact TradingMarkets at support@tradingmarkets.com to request the removal of this information from our database.

Security
We take every precaution to protect our customers’ information. When customers submit sensitive information via our website, their information is protected both online and off-line.

When our registration form asks users to enter sensitive information (such as credit card number), that information is encrypted and is protected with the best encryption software in the industry – SSL. While on a secure page, such as our order form, the lock icon on the bottom of Web browsers such as Microsoft Internet Explorer becomes locked, as opposed to un-locked, or open, when users are just ‘surfing’.

We also do everything in our power to protect user-information off-line. We restrict all of our customers’ information to our offices, and only employees who need the information to perform a specific job (for example, our billing clerk or a customer service representative) are granted access to personally identifiable information. Our employees must use passwords to access the information and are kept up-to-date on our security and privacy practices. Finally, the servers that store personally identifiable information are kept in a secure environment.

If you have any questions about the security at our website, please contact us via e-mail at to support@tradingmarkets.com.

Supplementation of Information
To fulfill our obligation to our customers, it is sometimes necessary that we supplement the information that we receive with information from third party sources.

Address Verification
We use RTWare software to verify a customer’s address before completing a charge on a credit card. This procedure protects our customers and us from credit card fraud and other illegal activities.

Purchasing History
In order for this Web site to enhance its ability to tailor the site to a user’s preference, we combine information about a customer’s purchasing habits to create a personalized customer profile.

Correcting/Updating/Deleting/Deactivating Personal Information
If a customer’s personally identifiable information changes (such as zip code, phone, e-mail or mailing address), or if a customer no longer desires our service, we provide a way to correct, update or delete/deactivate the customer’s personally identifiable information. This can usually be done at the member information page, by e-mailing our Customer Support at support@tradingmarkets.com or by contacting us by telephone or postal mail at the contact information listed below.

How Long Do We Retain Your Personal Data?
We retain Personal Data about you as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

6. Your Legal Rights

Under data protection laws you have rights in relation to your personal data that include the right to request access, correction, erasure, restriction, transfer, to object to processing, to the portability of data and (where the lawful ground of processing is consent) to withdraw consent.

You can see more about these rights at:

https://ico.org.uk/for-organisations/guide-to-the-general-data-protection-regulation-gdpr/individual-rights/

If you wish to exercise any of the rights set out above, please email us at info@cg3.com

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive or refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you.

If you are not happy with any aspect of how we collect and use your data, you have the right to complain to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We should be grateful if you would contact us first if you do have a complaint so that we can try to resolve it for you.

Notification of Changes
If we decide to change our privacy policy, we will post those changes to this privacy statement, the homepage, and other places we deem appropriate so our customers are always aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

Contact Information
If you have any questions or suggestions regarding our privacy policy, please contact us at:

The Connors Group, Inc.
185 Hudson St.
Suite 2500
Jersey City, NJ 07311
1-973-494-7311 ext. 1
info@cg3.com