Privacy Policy

SIGNAL TRADING GROUP

Privacy Notice

This Privacy Policy is effective as of October 1, 2018.

This Privacy Policy (“Policy”) describes the practices Signal Trading Group, LLC (“Signal Trading Group”, “we” or “our”, with respect to the personal data provided by, or collected from, visitors, trial members or members of its website www.signaltradinggroup.com, blogs, webinars, our social media pages and other services (collectively “Platform”) or that is gathered from email correspondence, from or about registrants or attendees at events, or through interactions with Signal Trading Group’s representatives (collectively “Services”). Visitor, member, registrant, attendee, each a “user” or “you”.

This Privacy Policy provides information so that users are able to understand, and as requested, consent to the processing of their personal data, where appropriate. Signal Trading Group is the data controller regarding all personal data processing conducted through the Platform.

1. Contact Information

The data controller is: Signal Trading Group, LLC
4550 Wesley Ct.
Mason, OH 45040 [Postal Address]

The Data Protection Officer is: David Stendahl [Name] info@sigtg.com [Contact details]

2. Categories of Personal Data Collected and Source of the Data
Signal Trading Group collects information that a user chooses to provide, for example, by completing a form to register as a new member, download a white paper or request a document. It also collects information by analyzing a user’s behavior on the Platform over time. This information is collected through cookies and similar technologies. For information about cookies see our Cookie Policy at Section 9.

The “Personal Data” that we collect and process through the Platform or in connection with the Services include:

Name, contact details

In various sections of the Platform, users are asked to provide information about themselves, such as their name, e-mail address, phone number, billing address and organization. This happens, for example, when a user wishes to download a white paper or request to sign up for a newsletter.

Payment information
If a user requests Services for which payment is required, the user is asked to provide payment information. This information is collected and processed by an external payment processor; it is not accessed or stored by Signal Trading Group.

Registered User Information
If a user registers to become a trail member or a member, we create an account in the name of that individual. Depending on the situations, we request:

• First and Last Name
• Email address
• Street address, including country
• Telephone number

Only the minimum amount of information necessary to operate or manage the account is mandatory.

To access the user account, the registrant is requested to choose a password.

Communication from Users
When a user completes an online form, visits our Platform (for example on social media), or when a user otherwise contacts us, by email, phone or text, we automatically collect and store certain information about that user and the user’s activities, as we receive from such user, for example:

• The user’s name and contact information;
• Information that the user provides to us;
• The user’s company information, if any;
• The nature of the communication;
• The purpose of the interaction, and the action we took in response to the user’s inquiry or request;
• Any action the user takes upon receipt of such communication (for example, whether the user registers to attend an event that we offer, or request to receive documentation);
• Demographic information.

The information collected in connection with each type of interaction is retained so that we can continue interaction with the requestor with respect to our Platform or Services.

Communications to Users
Unless we are prohibited by applicable law from using cookies and a user has not otherwise consented to our use of cookies, we insert cookies in some of our correspondence.
In that case, when we send an email message to a user, our message contains images or links that when viewed or clicked, allow us to know whether the user has accessed or declined to open our message. This action also stores a cookie that allows us to count unique clicks or visits and potentially track the recipient.

This information helps us understand how the individual reacts to our communications and limit the amount and nature of information provided.

Surveys and Contests
From time-to-time, we invite users to participate in surveys or contests. Participation is voluntary. These surveys are organized for the purposes of our marketing efforts. When a user participates, we request certain personal data such as name and email address.
This is necessary to ensure that responses are categorized properly and are not duplicated. Depending on the nature of the survey or contents, we also use this information to send the survey results to the participants, or, if applicable, to notify contest winners and award prizes.

We also use the information in aggregate form, for analytics purposes, to understand our market, to monitor site traffic or app usage, or to modify our Platform or our Service to meet the needs or interests of users.

If we use a third-party service provider to conduct these surveys, the information collected by the service provider is subject to both the service provider’s privacy policy and ours. We will provide information about the applicable privacy policies with the Survey rules and will seek your explicit consent to these rules when required by law. You should read the terms of the survey or contest to understand the extent to which the service provider is allowed to use or reuse the information collected.

Social Media
Our Platform offers integrations with third-party social media platforms. These services collect the user’s IP address and which page of our Platform the user is visiting. They set a cookie to enable their features to function properly. Social media features and widgets are hosted by a third party or directly on our website. Your interactions with these features are governed by the privacy policy of the company providing the feature.

Publicly Available Data
We also collect information available from publicly available directories, and information that has been made available be an individual on public for a, such as information about a person’s interests.

Other information
Certain areas of the Platform include free text fields, where you can write messages to other users, or post content that contains Personal Data. We request that you do not disclose:

• Any data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data or data concerning your health, sex life or sexual orientation
• Any social security number, national Identification number, financial account information or any other information that might be deemed highly sensitive or confidential.
• Any data related to other persons.

Log Data
When a user uses, or interacts with our Platform, or clicks on a link that directs the user to our Platform, the user’s browser automatically provides, and we automatically collect and store, certain information about the user’s device (computer, tablet, smartphone) and the user’s activities. This includes:

• Preferences and settings: time zone, language, and character size;
• Identifiers: IP address
• Technical information: type of device, operating system name and version, device manufacturer, browser information (type, version), screen resolution;
• Coarse Geographic information: geographic location derived from the IP address.
  We collect this data for the proper operation of our Platform. Until the user registers with us, this data cannot be linked to a specific individual.

Traffic Data
Data generated by the use of the Platform also include:

• Information about use of the Platform: date stamp, URL of the visited page, URL of the last webpage visited before visiting our Platform or a website using our Platform. URL of the last webpage visited before visiting our Service;
• History of interaction with our webpages: pages viewed, time spent on a page, click through, clickstream data; queries made, search history, search results selected; comments made, type of service requested, purchases made. (for EEA users, if the user has accepted profiling cookie)

3. Purposes of processing
We use Personal Data for the following purposes:

Service

• To allow registered members to create and maintain their, verify the member’s identity and assist user if he/she misplaces or forgets his/her login or password;
• To respond to users’ inquiries, allow users to sign up for newsletters, request white papers, or other information, in order to contribute to or download Signal Trading Group white paper or content;
• To finalize purchase orders and deliver a Services to the user;
• To carry out market research and surveys;
• For interaction on social media;

Marketing

• For marketing purposes via e-mail, text, phone, instant messaging, regarding Signal Trading Group’s products and services, or those of selected third parties, such as sponsors; (with limitations for users located in certain countries such as the EEA or Canada)
• To interact with existing customers by sending marketing communications regarding products and services that are identical or similar to those the user has previously purchased or requested via the Platform

Profiling

• To create a profile of a person as a Platform user, through the use of profiling cookies and by collecting and analyzing information on the user’s interest in order to serve to each information and advertisements relevant to that user. All algorithms involved in this processing are regularly tested, to ensure the processing’s fairness and control for bias; (with limitations for users located in the EEA).

Analytics

• For development and administration of the Platform, to improve Signal Trading Group’s offerings and troubleshoot any technical issues which arise in connection with the use of the Platform (“Analytics”); (with limitations for users located in the EEA)

Misuse or Fraud

• To prevent and detect any misuse of the Platform, or any fraudulent activities carried out through the Platform (“Misuse/Fraud”).

4. Legal Basis for the Processing
The EU General Data Protection Regulation requires that we provide information to EEA users about the legal ground for the processing of their data. This section applies only to users who are in the EEA.

The grounds on which we rely to process Personal Data, according to the purposes identified include the following:

5. Categories of Recipients
We share Personal Data with the following entities:

Except as described below, Signal Trading Group will not share or disclose personal data with or to third parties.

We believe that our practices below are fair, lawful, and proportional in light of the legitimate interests and needs of our business, our legal obligations, and our obligations under our contracts; that they fairly address each individual’s legitimate rights and expectations in view of the context and purpose of the collection and use of the information collected; and are not intrusive or contrary to individuals’ rights.

Disclosure to Marketing Partners
In countries where such activities do not require prior explicit consent of a user, we provide personal information of individuals to third party marketing companies, affiliates, advertising agencies, and data aggregation companies. These partner firms use this information to provide individuals with information on products and services of interest.
In countries, such as in the European Economic Area, where such activities are restricted, we conduct these activities in accordance with applicable local laws.

Service Providers
We share information with our suppliers, subcontractors, and other third parties who provide services to us (collectively “service providers”) in connection with hosting, data analytics, information technology and infrastructure, order fulfillment, email delivery, auditing, and other related activities as necessary to perform the Services that the Customer purchased and to comply with our legal or contractual obligations. We provide only the information such service providers need to perform their designated functions. Our contracts with them prohibit them from using or sharing with others the information that we provide to them, or that they collect directly for purposes other than as directed by us.

Affiliated Entities
We share information with entities that are under common ownership or control of our parent company (“Affiliates”). Subject to local law requirements, express preferences indicated by individuals, or our contractual obligations the terms of this information is used to promote the services offered by our Affiliates and for the purposes described in this Privacy Notice.

Fraud Prevention and Protection of Legal Rights
We use and disclose information to the appropriate legal, judicial or law enforcement authorities and our advisors and investigators (i) when we believe, in our sole discretion, that such disclosure is necessary to investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of Signal Trading Group, its Customers, Customer Parties, or others; (ii) when an individual has abused the Services, exceeded the permitted use of the Service, gained unauthorized access to any Tool, engaged in spamming, denial of service attacks, use of malicious code, or similar attacks; (iii) to exercise or protect legal rights or defend against legal claims; or (iv) to allow us to pursue available remedies or limit the damages that we sustain.

Law Enforcement
We will disclose Personal Data if a court, law enforcement or other public or government authority with appropriate jurisdiction so requests, and we believe, in our reasonable discretion, that such request was made in compliance with applicable law.

Corporate Reorganization
We transfer Personal Data to a third party in case of the reorganization, sale, merger, joint venture, assignment, transfer or other disposition of all or any portion of our business, asset or stocks, including in the event of bankruptcy or corporate restructuring. Except as otherwise provided by a bankruptcy or other court, the use and disclosure of all transferred Personal Data will be subject to policies that are consistent with the policies described in this Privacy Notice. Any information that any individual submits or that is collected after that transfer is subject to a new privacy policy adopted by the successor entity.

6. Retention of Personal Data
The EU General Data Protection Regulation requires that we inform users of the length of time for which we retain the information that we collect.

7. Cookies
In some countries, the law requires us to provide you with detailed information about the cookies that are be set when you visit our Site. The law also requires that we obtain your consent to the use of certain types of cookies. This Cookie Policy aims to provide you with information about cookies, how we use them, and when applicable law how we request your consent.

What are “cookies”?
Cookies are small text files that are sent to a user’s browser by the website visited or when an email is opened. They are used for numerous different purposes, including to remember a user’s actions and preferences (for example, login data, language, font size, other display settings, etc.), so that the user does not have to configure them again when visiting again the website, or when moving from page to page within a website. Some operations within a website will not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website. They also contain a unique ID code that allows tracking a user’s browsing activities within a website, for statistical or advertising purposes.

Cookies are often divided in two categories, “session cookies” which are automatically deleted when you close your browser, and “persistent cookies” which remain on your device until their pre-set expiration period expires.

When browsing a website, you will receive first party cookies, which are sent by the website or third party cookies, which are sent from websites or web servers other than the website being visited.

You can find more information about cookies at this website: www.allaboutcookies.org.

Users Located in the EEA
Users located in the EEA have the right to prohibit the use of certain cookies. Technical cookies such as cookies used to allow users to login, and functional cookies, such as those used to remember choices made by a user when accessing the website usually do not require prior consent.

However, cookies used to create profiles on users and to send advertising messages that take into account the preferences revealed by users while browsing websites usually require prior consent from users located in the EEA.

Technical Cookies v. Profiling Cookies
For some types of cookies, the consent of the website user is unnecessary. This is the case for “technical cookies” which are only used to send messages through an electronic communication network, or are needed to provide the user with the service that the user requests: this includes browsing or session cookies, which are used to allow the user to login, and functional cookies, which are used to remember choices made by a user when accessing the website, such as language, fonts, settings, or to remember the products selected for purchase. These cookies are essential for the proper operation of the functions offered by the website.

Some cookies, known as “profiling cookies” are used to create profiles of users, and to send advertising messages to users in line with the user’s preference inferred from the user’s browsing the website. Certain laws, such as laws that apply to individuals in the EEA, require the affirmative consent of users.

How we Obtain your Consent (for users in the EEA)
The first time you visit our Site or at any other time after you have deleted our cookies from your device, you will be presented with a notice informing you that the Site uses cookies, in accordance with applicable law. That notice will include a link to our Cookie Policy (which is set forth in this section).

If the notice contains a request to agree to the use of our profiling cookies, we will use these cookies if you express your consent by clicking on the appropriate box. If you decide to continue through our website after being presented with that notice, without clicking on the appropriate box, we will assume that we do not have your consent to set cookies as described in this policy.

First Party Cookies
Our website uses technical cookies for website operations and to allow users to use the website content and services, to activate website functions, and to configure the website according to the user’s choice, such as language or font size. We also use analytics cookies, which allow us to understand how users use the website and to track traffic to and from the website, and profiling cookies to observe the user’s activities on the website to infer the user’s preferences, and send advertising messages in line with these preferences.

Analytics Cookies
We use Google Analytics to collect information that permits evaluation of the use of the Website, and analysis of user’s behavior and improvement of user experience. Information about how to opt out of being tracked by Google Analytics is available at: https://tools.google.com/dlpage/gaoptout.

Third Party Cookies
We use third party cookies, owned by third parties, which act either as independence data controllers regarding their own cookies. These cookies allow the collection of information about you so that we can send advertisements to you when you visit other websites.
You may opt-out of being tracked by these cookies. The opt-out may be provided through specific opt-out cookies. Please note that:

• using a new computer or a different browser, upgrading certain browsers, or modifying or erasing a browser’s cookie file, may clear an opt-out cookie.
• there are many more companies listed on these sites than those that place cookies on your device when you access our Platform.
• opting out of receiving interest-based advertising does not block all advertisements served to your device. You will continue receiving advertisements, but these advertisements will be generic or based on the content of a webpage that you are visiting, instead of being targeted to your specific interests.

• To Control Advertising on Websites
You are able to block the use of some cookies that are used to create a profile about you. For further information see:

Digital Advertising Alliance:
http://www.aboutads.info/choices/
http://www.aboutads.info
http://www.aboutads.info/consumers

Europe: http://youronlinechoices.eu

Network Advertising Initiative:
http://www.networkadvertising.org/choices/
http://www.networkadvertising.org
http://www.aboutads.info/consumers

Disabling or blocking cookies
You can also delete cookies at any time using the settings of your browser. Please review the “Help” section of your browser.

CAUTION: If you block or delete technical and/or function cookies used by the website, the website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.

Cookies present on the Site

We use the following types of cookies:

• Browsing or session cookies: these cookies are strictly necessary for the operation of the website, and/or to allow the user to use the website content and Services.
•  Analytics cookies: these cookies provide information that is used to understand how a website is used, and to track traffic to and from a website.
• Functional cookies: these cookies are used to activate specific functions and to configure webpages according to the user’s preference such as font size or language.
• Profiling cookies: these cookies are used to observe a user’s interest based on activities on a website, and to send advertisements that take these preferences into account.

Cookies present on the site are:

8. Choices Regarding Cookies and Advertising

Cookies
You may choose to block our Platform and other sites from setting cookies by changing the settings of your browser. Please note that blocking or disabling certain cookies may interfere with certain functionalities of some parts of our Platform.

To learn more about cookies, you may wish to refer to.
All About Cookies: http://www.allaboutcookies.org/
Cookie Central: http://www.cookiecentral.com/faq/
Network Advertising: http://networkadvertising.org/.

To obtain information specific a browser you can refer to
Explorer: http://support.microsoft.com/kb/196955
Firefox: http://support.mozilla.org/en-US/kb/Cookies
Google Chrome: http://support.google.com/chrome/bin/answer.py?hl=en&answer=95647
Opera: http://www.opera.com/browser/tutorials/security/privacy/
Safari: http://support.apple.com/kb/ph5042
Safari iOS: http://support.apple.com/kb/ht1677
Android: http://support.google.com/android/bin/answer.py?hl=en&answer=1722193
Blackberry: http://docs.blackberry.com/en/smartphone_users/deliverables/32004/Turn_off_cookies_in_the_browser_60_1072866_11.jsp
Windows Phone: https://support.microsoft.com/en-us/help/4027978/microsoft-account-control-privacy-settings-for-your-microsoft-account

CAUTION: If you block or delete technical and/or function cookies used by the website, the website may become impossible to browse, certain services or functions of the Website may become unavailable or other malfunctions may occur. In this case, you may have to modify or manually enter some information or preferences every time you visit the Website.

Interest-based Advertising
We use information collected about a user’s use of our Platform to arrange for advertisements about our Service to be served to a user on third party’s websites in accordance with our e-Marketing Policy. To do so, our advertising service provider places or recognizes a unique cookie on the user’s browser and uses other techniques, such as pixel tags.

If you would like more information about this practice and to learn about your choices, please visit
http://www.aboutads.info or
http://www.networkadvertising.org.

Opt-out of Targeted Advertising
You may opt-out of receiving targeted advertising as explained below. The opt-out may be provided through specific opt-out cookies. Please note that using a new computer, using a different browser, upgrading certain browsers, or modifying or erasing a browser’s cookie file, may clear an opt-out cookie.

Please note that opting out of receiving interest-based advertising does not result in block all advertisements served to your equipment. You will continue receiving advertisements; these advertisements will be generic or based on the content of a webpage that you are visiting, instead of being targeted to your specific interests.

Please bear in mind that there are many more companies listed on these sites than those that place cookies on your device when you access our Platform.

Digital Advertising Alliance:
http://www.aboutads.info/choices/
http://www.aboutads.info
http://www.aboutads.info/consumers
Europe: http://youronlinechoices.eu

Network Advertising Initiative:
http://www.networkadvertising.org/choices/
http://www.networkadvertising.org
http://www.aboutads.info/consumers

9. Security

Security of Personal data
We use commercially reasonable technical, organizational, and administrative safeguards to protect information within our control against unauthorized or unlawful access, use, modification, destruction, processing or disclosure, and against accidental loss, destruction, or damage. We believe that these measures are reasonably adapted to the nature of the information in our custody.

We limit access to our users’ personal data to only those employees and third parties who reasonably need access to it to perform the activities attached to their job responsibilities.
However, due to the realities of data security, no security system or storage system can be guaranteed to be 100% effective or secure. Thus, we cannot guarantee that any information provided to us or collected by us will not be accessed, hacked, disclosed, altered, or destroyed by unauthorized parties.

Breach of Security
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 might have been compromised), or if you suspect someone else is using your account, please let us know immediately by contacting us as indicated in the “How to Contact Us” section.

Lost or Stolen Information
You must promptly notify us if your credit, bank, other financial institution information, username, or password is lost, stolen, or used without permission. In such an event, we will assist you in updating your account details.

10. Transfers of Personal Data
Personal Data is collected and processed in several different countries. We provide services to individuals, users, or customers located across the globe. Subject to applicable law, the personal data that we obtain from or about Individuals is processed or transferred to data centers located throughout the world. The standards and laws that apply to the protection of personal data in these countries may be different from that which is afforded in the country where a is located.

Individuals who are in the EEA and who request access to our services and platform are required to explicitly consent the propose transfer or processing of their personal data outside the EEA.

11. Rights of Individuals Located in the European Economic Area
The EU General Data Protection Regulation (GDPR) grants individuals who are in the European Union and European Economic Area (EU/EEA) the following rights, with some limitations. Users may contact us, at the address provided in the “How to Contact us” section below, to exercise any of those rights and we will respond with the requested action or information, or will let you know why that right does not apply to you.
Right Not to Provide Consent or to Withdraw Consent

We seek to rely on your consent in order to process certain personal data. Where we do so, you have the right not to provide your consent, and the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of the processing conducted based on consent before its withdrawal.

Right of Access
You have the right to obtain confirmation as to whether or not we collect or process personal data concerning you and, if this is the case, you have the right to request a copy of such personal data in digital format.

Right of Rectification
You have the right to require that we correct any inaccurate personal data concerning you, and that we complete incomplete personal data.

Right of Erasure
In certain circumstances, you have the right to request that we erase personal data concerning you; for example, if it is no longer necessary for the purposes for which it was originally collected.

Right to Restrict Processing
In certain circumstances, you have the right to request that we restrict the processing of the personal data that we have collected about you; for example, where you believe that the personal data that hold about you is not accurate or lawfully held.

Right to Data Portability
In certain circumstances, you have the right to receive the personal data concerning you that you have provided us in a structured, commonly used, machine readable format, and the right to obtain that we transmit the data to another entity where technically feasible.

Right to Object to the Processing
In certain circumstances, you have the right to request that we stop processing your personal data.

Right to Object to the Processing for Direct Marketing Purposes
You have the right to request that we stop sending you marketing communications.

Right Not to be Subject to Decisions Based Solely on Automated Processing that Produce Legal Effects
In certain circumstances, you have the right no to be subject to a decision based solely on automated processing – including profiling – that produces legal effects or similarly affects you.

Right to Complain to a Supervisory Authority
You have the right to lodge complaint with a supervisory authority if you believe that our processing of personal data relating to you infringes the GDPR.

12. Rights of Users Located in California Residents
California requires operators of websites or similar services to make certain disclosures to users who reside in California regarding their rights, specifically:
Shine the Light

Under California law, a business that has an established business relationship with an individual, and has, within the immediately preceding calendar year, disclosed personal data that is primarily used for personal, family or household purposes to third party for the third party’s direct marketing purposes, must disclose to its California users, upon request, the identity of any such third party, along with the type of personal data disclosed.

You can contact us to as provided in the “How to Contact Us” section. Please note that under California law, businesses are only required to respond to a user’s request once during any calendar year.

Do-Not-Track
Some browsers give individuals the ability to communicate that they wish not to be tracked while browsing on the Internet. California law requires that we disclose to users how we treat do-not-track requests. The Internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance with “Do Not Track” would be measured or evaluated, or a common approach to responding to a “Do Not Track” signal. Due to the lack of guidance, we have not yet developed features that would recognize or respond to browser-initiated Do Not Track signals in response to California law.
In the meantime, there are technical means to prevent some of the tracking, if any. See Section “Your Advertising Choices.”

13. Children’s Privacy
Our Platform is not directed to individuals under the age of 18. We do not solicit or knowingly collect Personal data from such individuals. If you become aware that a child has provided us with personal data, please contact us as indicated in the “How to Contact Us” section below. If we obtain actual knowledge that we have collected Personal data from a child under the age of 18, we will take steps to delete such information from our database.

14. Amendments
We reserve the right to amend or update this Policy at any time. We will inform you of such changes as soon as they are introduced, and they will be binding as soon as they are published on the Platform or later, as provided by applicable law. Please regularly visit this page to acquaint yourself with the latest, updated version of the Privacy Policy.

15. How to Contact Us
The data controller is Signal Trading Group, LLC with a principal business address at:

4550 Wesley Ct
Mason, OH 45040

Communications, questions and comments can be sent to infoATsigtgDOTcom (Please replace “AT” with @ and “DOT” with .)