Privacy Policy

Children

We do not intend to, and do not knowingly, process Personal Information about individuals who are minors in the jurisdictions where they reside (Children). Individuals who are Children should not provide any Personal Information to us, and individuals should not provide Personal Information to us about Children. If we discover or are informed that we have Personal Information about Children, we reserve the right to delete that Personal Information from our systems.

Personal Information We Collect

TradeDots provides trading signals, portfolio management tools, and market analysis (Products) to anyone who creates an account with us (Clients). In the course of providing the Products, TradeDots receives from Clients, itself collects, and processes Personal Information.

Device Information

When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to this automatically-collected information as "Device Information".

We collect Device Information using the following technologies:

• "Cookies" are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
• "Log files" track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
• "Web beacons", "tags", and "pixels" are electronic files used to record information about how you browse the Site.

Order Information

Additionally, when you make a purchase or attempt to make a purchase through the Site, we collect certain information from you, including your name, email address, phone number, and payment information (including credit card numbers). We refer to this information as "Order Information". Please note that TradeDots does not store or has access to your complete payment and credit card information as we use a third-party payment processor to process all such payments.

When we talk about "Personal Information" in this Privacy Policy, we are talking both about Device Information and Order Information.

Personal Information may include the following: (1) identifiers, such as first and last name, email address, billing address, and phone number; and (2) financial information processed by our third-party payment processor.

Depending on how you interact with us, we may collect Personal Information when you: (1) visit the Site; (2) subscribe for the Products by creating an account using the Site; (3) communicate with us directly or indirectly via email or the chat function available on the Site; and (4) otherwise interact with us.

TradeDots has collected Personal Information in the last twelve months and processed it for the purposes described in this Policy.

Sensitive Personal Information

TradeDots does not intend to, and does not knowingly process Personal Information that is of a sensitive nature (Sensitive Personal Information). If we discover or are informed that we have Sensitive Personal Information, we reserve the right to delete that Sensitive Personal Information from our systems.

Legal Bases for Processing Personal Information

TradeDots processes Personal Information to perform our contractual and other commercial, business, and legal relationships with and obligations to provide Products to Clients. As a result, Clients provide Personal Information to TradeDots and TradeDots collects and processes Personal Information in order to provide Products to Clients. In addition, TradeDots seeks and obtains consent for the use and processing of Personal Information when required by Data Privacy Laws. Those are the legal bases for TradeDots to process Personal Information.

How We Use Your Personal Information

We use the Order Information that we collect generally to fulfill any orders placed through the Site. Additionally, we use this Order Information to:

• Provide, develop, maintain, and enhance the Products and the Site
• Fulfill your requests when you subscribe for the Products
• Communicate with you about the Products
• Provide support for the Products including responding to requests, questions and feedback
• Process and complete transactions, and send related information, including purchase confirmations and invoices
• Personalize your experience with the Site
• Send you marketing and promotional communications that we believe may be of interest, such as information about our Products, features, offers, catalogues, promotions, and events (when in line with the preferences you have shared with us)
• Screen our orders for potential risk or fraud
• Set up your accounts with our products
• Display information using third party apps on our website
• Maintain the safety, security, and integrity of our Products and the Site
• Comply with legal and regulatory obligations
• Establish, enforce, and otherwise exercise our rights and defend against claims

We use the Device Information that we collect to help us screen for potential risk and fraud (in particular, your IP address), and more generally to improve and optimize our Site (for example, by generating analytics about how our customers browse and interact with the Site, and to assess the success of our marketing and advertising campaigns).

Sharing Your Personal Information

Except as necessary or appropriate to provide Products to Clients, TradeDots does not disclose Personal Information about you to other Clients or unaffiliated third parties, provided that we may disclose Personal Information for the following purposes and in the following circumstances:

• If directed to do so by the individual about whom such Personal Information pertains or that individual's legal representative
• If required to do so by Data Privacy Law, any other law, rule, or regulation, legal process or warrant, or order of any court or governmental agency or authority
• To third parties necessary or appropriate to provide the Products, such as information technology and security providers, data hosting services, providers that process payments, or any other third party that is necessary or appropriate for TradeDots to disclose Personal Information to in order to provide the Products
• To professional service providers, including attorneys, accountants, tax professionals, and financial advisers, if doing so is necessary or appropriate to obtain professional services from them
• In connection with a sale, merger, consolidation, change in control, transfer of substantial assets, reorganization, or liquidation of TradeDots
• To entities that perform marketing, advertising or market research on our behalf

We also use Google Analytics to help us understand how our customers use the Site. You can read more about how Google uses your Personal Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.

Privacy Rights

Depending on the Personal Information that TradeDots has about you, and depending on the manner in which we process your Personal Information, you may have the following privacy rights related to our processing of your Personal Information:

• Be informed about how your Personal Information is being processed, the categories of Personal Information being processed, and the categories of sources from which your Personal Information has been collected
• Be informed about whether and how your Personal Information being processed is being sold, shared, traded, exchanged or brokered with unaffiliated third parties, and which categories of your Personal Information are being sold, shared, traded, exchanged or brokered with unaffiliated third parties
• Access or receive a copy of your Personal Information
• Rectify, update or correct inaccurate or incomplete Personal Information about you
• Erasure or deletion of certain categories of your Personal Information
• Object and opt-out of processing of your Personal Information
• Limit processing of your Personal Information
• Opt-out of the sale, sharing, trading, exchange, and brokering of your Personal Information with unaffiliated third parties
• Portability of your Personal Information in a commonly used format
• Withdrawal of your consent to processing of your Personal Information to the extent such processing is based on your consent, provided that such withdrawal will not affect the lawfulness of TradeDots's use of your Personal Information before such withdrawal
• Non-discrimination for exercising your privacy rights

To make a request concerning these rights, please contact us at support@tradedots.ai. We will confirm receipt of all such complete requests within 10 days of receipt. We will substantively respond to all such requests within 30 days, subject to any lawful extension of that period. Additionally, there may be a delay in processing a request while we verify that the request is valid and originates from you as opposed to an unauthorized person.

Please be aware there may be valid reasons to refuse a request, including legal and regulatory requirements that we retain and process certain information. Also, please be aware that certain requests may limit or prevent us from providing Products to you. In those situations, we will notify you in writing within 30 days.

TradeDots will not discriminate against you if you exercise any of the foregoing rights or any other rights under Data Privacy Laws, including, by not denying Products to you, not providing a different level or quality of Products to you, and not suggesting that you will receive a different level or quality of Products.

European Residents

If you are a European resident, you have the right to access personal information we hold about you and to ask that your personal information be corrected, updated, or deleted. If you would like to exercise this right, please contact us through the contact information below.

Additionally, if you are a European resident we note that we are processing your information in order to fulfill contracts we might have with you (for example if you make an order through the Site), or otherwise to pursue our legitimate business interests listed above. Additionally, please note that your information will be transferred outside of Europe, including to the United States.

California Residents

California Civil Code Section 1798.83, also known as the "Shine The Light" law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Site, you have the right to request removal of unwanted data that you publicly post on the Site. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Site, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g. backups, etc.).

Selling, Sharing, Trading, Exchanging and Brokering Personal Information

Except as otherwise disclosed in this Policy, TradeDots does not sell, share, trade, or exchange Personal Information (including as those terms are defined and used in Data Privacy Laws) in any way, including for itself, or any unaffiliated third party. If and to the extent you want to opt-out of the sale, sharing, trading, or exchanging of your Personal Information, please contact us at support@tradedots.ai, and we will address such requests as described in the Privacy Rights section of this Policy.

Automated Decision Making

TradeDots does not use automated decision making or profiling in the processing of your Personal Information, and does not make decisions that affect you based on automated decision making or profiling using your Personal Information.

Cookies

When you visit the Site, TradeDots may place a cookie (a text file containing a randomly assigned number) on your device so that we have the ability to customize the look and feel of the Site for you. Cookies remember information about you, your preferences, and your device for a better user experience when visiting the Site. Using cookies, we may also collect a variety of other information regarding your usage of the Site, including your Internet protocol address, username, session identification, browser you are using, web pages you view and referring web pages, when you access the Site, and general online behavior for performance and marketing purposes.

You may decline to accept cookies by modifying your web browser settings. If you choose so, however, you may be unable to use all functions of the Site, or the Site may operate less efficiently.

Data Retention

When you place an order through the Site, we will maintain your Order Information for our records unless and until you ask us to delete this information.

Because the Products that TradeDots provides to Clients vary significantly, the duration we retain Personal Information varies significantly, depending on the types of Products that TradeDots provides to particular Clients, the duration and depth of TradeDots's relationship with particular Clients, and the nature of Personal Information in question. TradeDots endeavors to retain Personal Information that it receives from or collects for only as long as is necessary or appropriate.

Data Security

We take reasonable measures to help protect information about you from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. However, no internet or electronic storage system is completely secure, so we cannot guarantee absolute security.

International Data Transfers

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the information, including Personal Information, to United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Changes to This Privacy Policy

We may update this privacy policy from time to time in order to reflect, for example, changes to our practices or for other operational, legal or regulatory reasons. TradeDots reserves the right to change or amend this Policy at any time and for any reasons, including to remain in compliance with Data Privacy Laws.

The updated version will be indicated by an updated "Last Updated" date and the updated version will be effective as soon as it is accessible. If we make material changes to this privacy notice, we may notify you either by prominently posting a notice of such changes or by directly sending you a notification. We encourage you to review this privacy notice frequently to be informed of how we are protecting your information.

Contact Us

For more information about our privacy practices, if you have questions, or if you would like to make a complaint or submit a privacy rights request, please contact us by email at support@tradedots.ai