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PRIVACY POLICY

Last Updated 01/02/2020

Market Life Trading, LLC and its affiliates (the “Company", also “we”, “us” and “our”) want you to be familiar with how we collect, use, and disclose information from and about you while you access and use Marketlife.com or any affiliated sites and/or their subdomains (collectively, the “Site”) and while you access and use any services on the Site. Each user of the Site (hereafter also “you” and “your”) agrees to use any content and services we provide through the Site, mobile sites, web and/or mobile applications, electronic newsletters and widgets (collectively the “Services”) in compliance with the Market Life Trading, LLC End-user Agreement (the “Agreement”), with the Company’s Acceptable Use Policy (“AUP”), with all applicable rules and regulations, including the local, state, national, and international laws that apply to your jurisdiction as well as with this Privacy Policy (the “Policy”).

We want to be familiar with how we collect, use and disclose information because we understand you are concerned about your privacy, and we want to maintain your trust. We hope this Policy helps you understand our privacy commitments to you. If you do not agree with the content of this Policy, then please remember it is your choice whether you want to use the Site and/or the Services.

1. INTRODUCTION

This Policy applies to information we collect from all sources including in connection with all Services that link to this Policy. If there is a conflict between this Policy and the Agreement, the Agreement will control.

This Policy describes the Company’s collection and use of users' Personal Information (as defined below). It also describes generally the Company’s practices for handling other Information (e.g., interests, demographics and service usage) collected through our Services or from a third party to the extent such information is associated with a particular device, user, or user account. By using the Site and/or the Services or by providing Personal Information to us, you agree to the terms and conditions of this Policy.

You may choose not to submit requested information online, or you may choose to restrict the use of cookies (see Other Information below for more information), but that may limit the Services we are able to provide to you.

The Services are provided via the Site, a network of websites and/or one or more desktop, web, and/or mobile applications, and are not targeted to, and do not knowingly collect Personal Information from, any person under 18 years of age. No one under age 18 may provide any Personal Information to or on the Services. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information via the Services or through any of their features. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at info@marketlifetrading.com

2. EUROPEAN UNION RESIDENT RIGHTS

Under the new European Union law, General Data Protection Regulation (“GDPR”), certain individuals are granted certain rights in relation to their personal data. If you a resident of the European Union, you have the following rights when submitting your personal data to us:

  • Right of Access – the right to be informed of and request access to the personal data we process about you;
  • Right to Rectification – the right to request that we amend or update your personal data where it is inaccurate or incomplete;
  • Right to Erasure – the right to request the deletion of your personal data;
  • Right to Restrict Processing – the right to request that we temporarily or permanently stop processing some or all of your personal data;
  • Right to Data Portability – the right to request your data in a structured, commonly used and machine-readable format and the right to transmit that personal data for use in another party’s service; and
  • Right not to be subject to Automated Decision-making – the right to not be subject to a decision based solely on automated decision making, including profiling, where the decision would have a legal effect on you or produce a similarly significant effect.

3. INFORMATION WE COLLECT

The Company and our service providers may collect the following information from and about you:

Personal Information

"Personal Information" for purposes of this Policy is any information relating to you as an identified or identifiable natural person. An “identifiable natural person” is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Personal Information from You

We collect Personal Information when, for example, you register for or subscribe to certain Services; create a profile; take a survey; visit the Site or the Services; use an interactive feature; participate in a community forum or trading room; or contact customer service.

Other Information

"Other Information" is any information that is not Personal Information, such as browser information, app usage data, information collected through cookies and other technologies, visit statistics including duration and click streams, demographic information, and aggregated information, including aggregated information about user behavior.

Other Information You Submit

We collect Other Information when you submit it to us. This may include your interests, investment or trading experience and/or preferences and other information we may solicit (and they you may choose to provider) in order to help provide and improve the Services.

Other Information We Receive from Third Parties

We may receive Other Information about you from third parties, including, for example, demographic data, information about your interests, and information about your activities on other websites.

Other Information We Collect Automatically When You Are Online

When you access and interact with the Services, we or our service providers may automatically collect certain information about those visits. For example, in order to permit your connection to the Services, our servers receive and record information about your computer, device, and browser, potentially including your IP address, browser type, and other software or hardware information. If you access the Services from a mobile or other device, we may collect a unique device identifier assigned to that device ("UDID"), geolocation data, or other transactional information for that device.

The Company and our service providers also may use cookies and other tracking technologies (such as browser cookies, pixels, and beacons) when you visit or use the Services. Third parties that may support the Services by various means such as serving advertisements, hosting affiliate referral programs, or providing services, such as providing users with the ability to comment on content, allowing users to share content, customizing content based on usage, or tracking aggregate site usage statistics, may also use these technologies to collect Other Information on the Services and on other websites.

Most browsers are initially set to accept cookies, but you can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the "Help" section of your browser for more information. Please note that by blocking any or all cookies you may not have access to certain features or personalization available through the Services. Please see the Cookies section of this Policy for more detail on Cookies.

4. HOW WE USE YOUR INFORMATION

We collect, use or otherwise process Personal Information as allowed under applicable law, including where based on one or more of the following:

  • The consent you provide to us at the point of collection of your Personal Information;
  • The performance of a contract we have with you;
  • The compliance of a legal obligation to which we are subject; or
  • The legitimate interests of the Company, a third party, or yourself.

"Legitimate interest" is a technical term under applicable regulations. It means that there are good reasons for the processing of your personal information and measures are taken to minimize the impact on your privacy rights and interests. "Legitimate interest" also references our use of your data in ways you would reasonably expect and that have a minimal privacy impact. We have a legitimate interest in collecting and processing personal information, for example and by way of illustration only: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business within the Company; and, (3) to prevent fraud.

We use the Personal Information we collect from and about you for the purposes set forth below. Please note that we may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law. If we are required to treat Other Information as Personal Information under applicable law, then we may use and disclose it for all the purposes for which we use and disclose Personal Information. We may combine Other Information with your Personal Information, and when we do, we treat the combined information as Personal Information.

To improve the quality of our products and Services and to personalize your experience by presenting content, products and offers tailored to you, we may also combine the Personal and Other Information we collect with information relating to your use of other of the Company’s products, Services and websites. In addition, we may supplement the Personal and Other Information we collect with information from other sources, such as publicly available information from social media services, commercially available sources and information from Company affiliates or business partners.

To provide and manage our Services. We use the information we collect from and about you to provide our products, Services and features to you, including: to process your registration and fulfill your requests related to the Services, to send you information about your relationship with us or your account, to measure and improve those Services and features, to allow you to participate in aspects of the Services and related resources, to share content and collaborate with other users, to provide you with customer support, and to respond to inquiries. If you choose to participate in a forum, trading room or other resource with synchronous or asynchronous messaging functionality, some of your Personal Information may be included in a directory that can be viewed and used by other members of that resource. In addition, if you make use of multiple service offerings, we may use your information to allow you to sign in to several Services, websites, applications, or other services with the same user ID and/or authentication information.

To deliver relevant content and recommendations. To make your experience more interesting and personalized, we may use any of the Personal and Other Information we collect to assist us in delivering content on any of our Services.

Analysis and Development of New Products and Services. We perform statistical, demographic and marketing analyses of users of the Services, and their usage patterns, so we can analyze or predict our users’ preferences for product and Services development purposes, to determine our promotional campaign effectiveness so we can adapt our campaign to the needs and interests of our users, and to generally inform potential advertisers and other business partners about the nature of our user base. We use this information for analytical purposes, including analysis to improve customer relationships, to support strategic business decisions and our marketing tactics and to measure and track our brand health. We may also engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, or because we have a legitimate interest in doing so.

Aggregating and/or Anonymizing Personal Information. We aggregate and/or anonymize Personal Information so that it will no longer be considered personally identifying. We do so to generate other data for our use, which we may use and disclose for any purpose.

To allow social sharing functionality. If you log in with or connect a social media service account with any of our Services, we may use Personal and Other Information to facilitate your sharing of information between our Services and your social media service.

To contact you. The Company and its affiliates may periodically send promotional materials, surveys, updates, announcements or notifications related to our products and Services. To help make these materials more relevant to you, we may use and combine any of the Personal and Other Information we collect to assist us in sending you these materials. We may also use your information to contact you, including to respond to your comments, inquiries or requests. If you want to stop receiving these materials from us, please follow the instructions in the Choices and Access section below.

To protect the rights of the Company and others. We may use your Personal Information as we believe to be necessary or appropriate in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of the Company, of the Company’s members, managers, officers, directors, employees, contractors, partners, suppliers, vendors, agents, licensors, subsidiaries, affiliates, successors and assigns (the “Company Persons”), including enforcement of our Agreement, other agreements, and our terms of use; (ii) protect the safety, privacy, and security of users of our products and Services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process, including laws outside your country of residence; or, (v) to respond to requests from public and government authorities including public and government authorities outside your country of residence.

5. HOW WE SHARE YOUR INFORMATION

Information Made Public Through Use of Our Services and User Privacy Settings

Certain features of the Services give you an opportunity to interact with us and with others. These may include collaboration tools, community forums, trading rooms, chats, creating profiles, and creating, rating, reviewing, tagging and commenting on content. When you use these features, you should be aware that any information you submit, including your name, user name, location, email address, profile information, picture, and comments you submit, may be publicly available to anyone, including other users, search engines, advertisers, third-party application developers, and anyone else with access to the Services. We are not responsible for any information you choose to submit and make public through these interactive features.

Our Disclosure of Information

The Company and subsidiaries licensors, licensees or affiliates, if any, may share your Personal Information with one another for the purposes described in this Policy, including for each company's marketing purposes.

In addition, we may share your Personal Information with non-affiliated third parties when sharing is permitted by you or authorized by this Policy, including:

To manage third-party registrations. If your registration for a Service is provided in whole or in part by a third party, we may notify the provider of such registration when you access or use your account. When providing these notices, we may reveal limited amounts of your Personal Information such as your name or email address.

To allow third-party service providers to assist us in providing and managing our Services. We may make your Personal Information available to certain third-party service providers, such as technical service providers, contractors, agents or sponsors, who help us manage or provide our products and Services by, for example: developing or supporting products and features; sending email messages on our behalf; auditing; processing data or statistics; and serving, customizing or delivering marketing or ads. These outside service providers are required to protect Personal Information entrusted to them and to not use it for any other purpose than the specific service they are providing to us.

Payment Processing. We may use a third-party payment service to process payments made through the Services. If you wish to make a payment through the Services, your personal information will be collected by such third party and not by us, it and will therefore be subject to that third party’s privacy policy, rather than to this Policy. We have no control over, and are not responsible for, any such third party’s collection, use, and disclosure of your personal information.

To provide co-branded Services, features or events. We may offer co-branded Services, features, or events, such as webinars or other promotions or in-person events together with a third party ("Co-Branded Services"). These Co-Branded Services may be hosted on the Site or the Services or on the third party's service. By virtue of these relationships, we may share the information you submit in connection with the Co-Branded Service with the third party. Any such third party's use of your information will be governed by such third party's privacy policy and not by this Policy.

To permit unaffiliated third parties to send you promotional materials. We may share your Personal Information with unaffiliated third parties for such parties' own marketing purposes only if you have given us permission to do so.

To allow social sharing functionality. If you log in with or connect a social media service account with any of the Services, we may share your username, picture, profile information as well as your activities and comments including “likes”, “follows”, reviews and the like with other Services users and with your friends associated with your social media service. We may also share the same information with the social media service provider. By logging in with or connecting your Services account and your social media service, you are authorizing us to share information we collect from and about you with the social media service provider, other users and your friends, and you understand that the social media service's use of the shared information will be governed by the social media service's privacy policy and not by this Policy. If you do not want your Personal Information shared in this way, please do not connect your social media service account with your Services account, and do not participate in social sharing on the Services.

To protect the rights of the Company and of others. There may be instances when the Company may disclose your Personal Information, including situations where we have a good faith belief that such disclosure is necessary in order to: (i) protect, enforce, or defend the legal rights, privacy, safety, or property of the Company, of Company Persons, of our affiliates or their employees, agents and contractors (including enforcement of the Agreement, our agreements and our terms of use); (ii) protect the safety, privacy, and security of users of our products and Services or members of the public; (iii) protect against fraud or for risk management purposes; (iv) comply with the law or legal process, including laws outside your country of residence; or (v) to respond to requests from public and government authorities including public and government authorities outside your country of residence.

To complete a merger, sale of assets, or bankruptcy. If the Company sells all or part of its business or makes a sale or transfer of its assets or is otherwise involved in a merger, bankruptcy, or transfer of all or a material part of its business, the Company may transfer your information to the party or parties involved in the transaction as part of that transaction.

6. SECURITY

The Company uses a combination of administrative, technical, personnel, and physical measures to safeguard Personal Information in its possession against loss, theft and unauthorized use, disclosure, or modification. However, no one can guarantee the complete safety of your information under any circumstances. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting Customer Service at info@marketlifetrading.com in accordance with the instructions below.

7. CHOICES AND ACCESS

Your Choices Regarding Our Use and Disclosure of Your Personal Information

We give you many choices regarding our use and disclosure of your Personal Information for marketing purposes.

You may opt-out from receiving electronic communications from us (including surveys, updates, announcements or notifications), or our sharing of your Personal Information with Company affiliates for their direct marketing purposes by changing your account settings through the appropriate link on the website or by following the unsubscribe instructions at the bottom of each email.

You may also opt-out from our sharing of your contact information with unaffiliated third parties for their marketing by adjusting security settings, where available, or by contacting Customer Service at info@marketlifetrading.com.

Please note that there are certain service notifications that you may not opt-out of, such as renewal notices and notifications of changes to Company products and Services or policies. If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app. You further acknowledge that you may not opt out of our sharing of that minimum amount of required Personal Information so that the Company, Company Persons or any of the Company’s affiliates may complete their legally-required tax filings.

How to Access, Correct or Update Your Personal Information

If you would like to request to review, correct, restrict or delete personal information that you have previously provided to us, object to the processing of personal information, or if you would like to request to receive an electronic copy of your personal information for purposes of transmitting it to another company (to the extent this right to data portability is provided to you by applicable law), you may contact Customer Service at info@marketlifetrading.com. Most registered users can also update their Personal Information online by signing on to their accounts and visiting the appropriate account management sections of the Site. Please note that if you have registered for more than one of our Services, you may need to update your information for each separately.

You may contact Customer Service at info@marketlifetrading.com at any time.

For your protection, we may only implement requests with respect to the Personal Information associated with the particular email address that you use to send us your request, and we may need to verify your identity before implementing your request.

We will respond to your request consistent with applicable law.

You may lodge a complaint with a data protection authority for your country or region or where an alleged infringement of applicable data protection law occurs. A list of EU data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

Please note that we may need to retain certain information for recordkeeping purposes and/or to complete any transactions that you began prior to requesting such change or deletion (e.g., when you subscribe to a Service, you may not be able to change or delete the Personal Information provided until after the completion of such Service).

Your California Privacy Rights

California Law permits users who are California residents to request certain information regarding our disclosure of Personal Information to third parties for their own direct marketing purposes. If you are a resident of California, under 18 and a registered user of the Services, you may ask us to remove content or information that you have posted to the Services. To make either request, please write to us at info@marketlifetrading.com and include your name and the address to which you would like us to respond.

8. SENSITIVE PERSONAL INFORMATION

Unless specifically requested (for example, in connection with a particular survey), we ask that you not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background or trade union membership) on or through the Services or otherwise to us. Any requested information that includes sensitive information about health, political opinions, ethnicity, race, religion, sex life or sexual orientation can unequivocally be left unanswered.

9. OTHER IMPORTANT INFORMATION

Do Not Track Disclosure. Some browsers or other tools include “Do Not Track” (“DNT”) features which, when turned on, send a signal to websites you visit indicating that you do not wish to be tracked across websites over time. The Worldwide Web Consortium (“W3C”) has been working with industry groups and regulators to develop a DNT browser technology standard to provide a common understanding as to how to interpret the DNT signals, but to date no standard has been adopted. Since there is no standard at this time, the Company does not currently respond to DNT signals. The Company will follow the progress of the W3C in developing the standard.

Data Retention. We retain personal information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law. The criteria used to determine our retention periods include:

  • The length of time we have an ongoing relationship with you and provide the Services to you (for example, for as long as you have an account with us or continue to use the Services);
  • Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
  • Whether retention is advisable in light of our legal position (for example, in light of applicable statutes of limitations, litigation or regulatory investigations).

Linked Services. The Services may also be linked to sites operated by third parties, and they may offer content or functionality developed and maintained by third parties. Some of these third-party sites may be co-branded with our logo, even though they are not operated or maintained by us.

The Company is not responsible for the privacy practices of any such third parties, and once you leave the Site and/or the Services, you should check the applicable privacy policy of the other, third-party service(s).

10. INTERNATIONAL TRANSFERS

MarketLife is headquartered in the United States. The information you provide to us or that we obtain as a result of your use of the Services is collected in your country and subsequently transferred to the United States or to another country in which we may have facilities or our affiliates may operate or in which we may engage service providers.

Notice. MarketLife complies with the EU-U.S. and the Swiss – U.S. Privacy Shield Frameworks as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. The Company has certified to the Department of Commerce that it adheres to the Privacy Shield Principles (WE CANNOT SAY THIS TILL WE SELF-CERTIFY). If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.

To learn more about the Privacy Shield program, and to view our certification, please visithttps://www.privacyshield.gov/.

Access to Personal Data and Dispute Resolution. In compliance with the Privacy Shield Principles, the Company commits to provide you with access to your personal information and the ability to correct, amend, or delete that information where it is inaccurate, or has been processed in violation of the Privacy Shield Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. The Company also commits to resolve complaints about our collection or use of your personal information. European Union and Swiss Individuals with inquiries or complaints regarding our Privacy Shield policy should first contact at: info@marketlifetrading.com.

The Company has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgment of your complaint from us, or if we have not resolved your complaint, please contact or visit JAMS (https://www.jamsadr.com/eu-us-privacy-shield) for more information or to file a complaint. The services of JAMS are provided at no cost to you.

You also have the possibility, under certain conditions, to invoke binding arbitration for complaints regarding Privacy Shield compliance not resolved by any of the other Privacy Shield mechanisms. For more information visit: https://www.privacyshield.gov/article?id=ANNEX-I-introduction.

Jurisdiction. The Federal Trade Commission has jurisdiction over the Company’s compliance with the Privacy Shield.

Note, however, that all considerations in this Section 10 are governed by the provisions of the Agreement including those provisions in the Agreement that pertain to dispute resolution, and in case of any conflict between this Policy and/or this Section 10 and the Agreement, the Agreement shall supersede and govern.

11. COOKIES

We may use cookies to personalize or enhance your user experience. Cookies are small pieces of text sent to your browser when you visit a site. They serve a variety of functions, like enabling us to remember certain information you provide to us as you navigate between pages on the Site. We use cookies to authenticate, personalize and secure your account as well as for analyzing performance and analytics.

You may, at any time, prevent the setting of cookies through our website by means of a corresponding setting of the Internet browser used, and may thus permanently deny the setting of cookies. Furthermore, already set cookies may be deleted at any time via an Internet browser or other software programs. This is possible in all popular Internet browsers. If the data subject deactivates the setting of cookies in the Internet browser used, not all functions of our website may be entirely used.

12. CHILDREN

The Services are not directed to children under the age of 18 years. However, in some countries, stricter age limits may apply under local law. Please see our Terms and Conditions for further details.

We do not knowingly collect personal data from children under 16 years or under the applicable age limit (the “Age Limit”). If you are under the Age Limit, please do not use the Services, and please do not provide any personal data to us.

If you are a parent of a child under the Age Limit and become aware that your child has provided personal data to us, please contact us at info@marketlifetrading.com, and you may request exercise of your applicable rights detailed in this Policy.

If we learn that we have collected the personal data of a child under the age of 16 years, we will take reasonable steps to delete such personal data. This may require us to delete the account for that child.

13. CALIFORNIA ONLINE PRIVACY PROTECTION ACT

The California Online Privacy Protection Act (“CalOPPA”) is the first state law in the nation to require commercial websites and online services to post a privacy policy. Compliance of the law is required by any company that reaches California consumers. According to CalOPPA, we agree to the following:

  • You may visit our site anonymously;
  • We will add a link to this Policy on our home page;
  • You will be notified of any privacy policy changes on our privacy policy page, through the “updated date” on the top of that page; and
  • You can change your personal information by emailing us at info@marketlifetrading.com.

14. UPDATES TO THE PRIVACY POLICY

The Company may modify this Privacy Policy from, time to time. Please look at the Last Modified Date at the top of this Policy to see when this Policy was last revised. Any changes to this Policy will become effective when we post the revised Policy on the Site and/or Services that link to this Policy. Your use of the Services or your provision of personal information to us following these changes means that you accept the revised Privacy Policy.

15. CAN-SPAM Compliant

We are CAN-SPAM compliant, which allows for you to request we stop sending you emails. Our emails contain “unsubscribe” options, which you may use to stop receiving emails from us. If you have any issues unsubscribing from our emails, please contact info@marketlifetrading.com.

16. CONTACT US

Thank you for reading our Privacy Policy. If you have questions about this Policy, please contact us at info@marketlifetrading.com.

We ask that you not disclose any sensitive Personal Information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, criminal background or trade union membership) when contacting us.