Privacy Policy

Trade-PMR Privacy Policy

This policy was last modified and is in effect as of September 7, 2023. This Privacy Policy is in effect for Trade-PMR, Inc. and its affiliates, including Portfolio Management and Research (collectively TradePMR). 

Introduction 

TradePMR respects your privacy, and we are committed to protecting the privacy and confidentiality of your Personal Data. By using or accessing our Services, you accept the practices and policies outlined below, and you consent that we will collect, use, and share your information as described in this Privacy Policy. 

This Privacy Policy governs the manner in which TradePMR collects, uses, maintains and discloses Personal Data collected when you access or use our Services. “Personal Data” means any information relating to an identified or identifiable natural person allowing for direct or indirect identification of that person's identity and includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules, or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage. 

In this policy, the word "customer" is used to mean any individual who obtains or has obtained a financial product or service from TradePMR as a provider of Services that involve compiling personal and sometimes sensitive information. Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Services. By accessing or using our Services, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our Services is deemed to be acceptance of those changes. 

Personal Data 

Categories of Personal Data We Collect 

We collect and have collected over the past 12 months the following categories of Personal Data about you: 

- Identifiers (e.g., name, mailing address, email address, phone number) 

- Characteristics of protected classifications (e.g., gender, age) 

- Commercial information (e.g., purchases, marketing collateral requested, webinar registrations) 

- Professional or employment-related information (e.g., employment status, employer) 

- Internet or other electronic network activity (e.g., browse or search history, interaction with a website, application, or advertisement) 

- Geolocation data (e.g., latitude or longitude) 

- Inferences drawn from other data collected or from the above (e.g., preferences or characteristics) 

Categories of Sources of Personal Data 

We collect Personal Data about you from the following categories of sources:

You

When You Provide Such Information Directly to Us 

- When you provide information in applications and related forms to obtain a financial product or service.
- When you provide information in free-form text boxes or respond to surveys.
-  When you contact us. 

When You Use our Services and Such Information Is Collected Automatically

- Through Cookies (see “Tracking Tools ” below). 
- If you use a location-enabled browser, we may receive information about your location and device.
- If you access certain applications and software we make available, we may receive and collect information transmitted from your device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices. 

Public Records or Sources 
Information from the media, and other records and information that are made available by federal, state, or local government entities 

Third Parties 
- Information obtained from other associations regarding any Service we may provide to you.
- Third-party reports, such as demographic and/or other information, if relevant to your Service. 
-  Information about your relationship with us, such as Services purchased, and/or account numbers, transaction information and balances.
- Analytics providers to analyze how you engage with the Services.
- Information to generate leads and create user profiles.
- Information to assist us with marketing or promotional services including how you interact with our websites, applications, products, Services, advertisements, or communications.

Our Commercial or Business Purposes for Collecting Personal Data 
We collect Personal Data about you for the following business purposes:

Providing, Customizing and Improving our Services 
- Creating and managing your account or other user profiles.
- Processing orders or other transactions.
- Providing you with the products, services, or information you request, including support and assistance for the Services.
- Improving the Services, including testing, research, internal analytics, and product development.
-  Personalizing the Services, website, and communications based on your preferences.
- Performing fraud protection, security and debugging.
- Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act (the “CCPA”).

Marketing our Services 
- Marketing and selling the Services. 
- Showing you advertisements, including interest-based or online behavioral advertising. 

Corresponding with You
- Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about TradePMR or our Services.
- Sending emails and other communications according to your preferences or that display content that we think will interest you.

Meeting Legal Requirements and Enforcing Legal Terms 
- Fulfilling our legal obligations, such as preventing, detecting, and investigating security incidents and potentially illegal or prohibited activities.
- Protecting the rights, property, or safety of you, TradePMR or another party.
- Enforcing agreements with you and resolving disputes.
- Responding to claims that any posting or other content violates third-party rights.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated, or incompatible purposes without providing you notice. 

How We Share Your Personal Data 
We disclose your Personal Data to the following categories of service providers: 

Service Providers who help us provide the Services or perform business functions: 

- Companies engaged to work with us, such as our clearing firm, third-party administrators and vendors hired to effect, administer, or enforce a transaction or service that you request or authorize; to facilitate enhanced customer service; to develop or maintain software; to perform marketing research; or to provide us with demographic information to develop marketing plans.
- Consumer reporting agencies in connection with your application or renewal of any Services subscribed or purchased.
- Analytics providers.
-  Payment processors.
-  We require these companies to maintain the confidentiality of your information and use it only for the purpose for which it was provided.

Your Advisor with whom you work with to obtain Services. 

Your Advisor’s successors and assigns for business and regulatory purposes after the termination of your customer relationship. 

Business Partners with which we share common ownership or who partner with us in offering various services, joint promotional offers, or opportunities. 

Advertising Partners who help us market our services: 

- Marketing providers. 
- Ad networks. 

Law enforcement and regulatory authorities to comply with federal or state law, statute, or regulation (i.e., in response to a subpoena, to prevent fraud, and to comply with rules of, or inquiries from industry regulators or law enforcement).

As a provider of a wide variety of Services, we may identify opportunities to enhance customer service or to offer our customers additional Services offered by TradePMR. However, we will not share information about our customers with others that could be used to make insurance underwriting or lending decisions about the customer, unless the customer directs us to or unless we notify the customer first and give the customer a chance to opt-out. In addition, we will not use certain Non-public Personal Data (such as income or account history) received from any affiliate to market its products or services to our customers unless directed to by the customer, or unless we notify the customer first and give the customer a chance to opt-out. Similarly, we will not share Non-public Personal Data with third-party financial services entities, such as banks, credit unions, credit union service corporations, insurance companies, or securities broker/ dealers, for purposes of joint marketing unless the customer direct us to, or unless we notify the customer first and give the customer a chance to opt-out.

We recognize that our customers’ relationship with their Advisor is important. If the customer is a participant of an employer sponsored plan, the customer’s Advisor may be under an agreement that restricts the transfer of the customer’s Personal Data and/or the customer’s employer sponsored plan account to any new firm. 

Data Security 

We use a combination of physical, technical, and organizational means to help safeguard Personal Data under our control. A user id and a password are needed to access certain Services. It is your responsibility to protect your username and password. 

We limit access to customer information to employees and your Advisor or agent, and their successors and assigns, who may need it to fulfill their obligation to you for the Services for which you have subscribed or purchased, or to comply with federal or state laws, statutes, or regulations.  

Employees of TradePMR are trained to respect the confidentiality of your Personal Data and are required to keep such information confidential and secure. 

Tracking Tools 

Our Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser or client, tell us how and when you access use our Services, analyze trends, learn about our user base and operate and improve our Services. 

Please note that because of our use of Cookies, our Services do not support “Do Not Track” requests sent from a browser at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com. 

Unless a user has not otherwise consented to our use of cookies, we insert cookies in some of our correspondence with users. We use these to collect information about you and your visit like date and time visited, length of time on site(s), pages visited, and general information about the device.  

We may use third parties to target relevant advertising on other sites based on your online activity and interests. For more information about interest-based advertising, please visit Digital Advertising Alliance or the Network Advertising Initiative.  

You can opt-out of seeing personalized ads by using the  DAA opt-out tool or the NAI opt-out tool. Please note you will still see ads even if you opt-out, but they will not be personalized.  

Google Analytics - We use a tool called “Google Analytics” to collect information about use of our website and our products. We use the information we get from Google Analytics only to improve our site and our products. We do not combine the information collected using Google Analytics with personally identifiable information.  For more information on how Google uses data when we use their partners’ websites or apps, visit https://policies.google.com/technologies/partner-sites. 

Your California Privacy Rights 

If you are a California resident, California law may provide you with additional rights regarding our use of your Personal Data. To learn more about your California privacy rights, visit  https://oag.ca.gov/privacy/privacy-laws and see the Privacy Notice for California Residents section of this Policy. 

Notice to European Users 

Our Services are targeted for users in the United States of America and Canada. Any information you enter regarding our Services may be transferred outside of the European Union to the United States of America which does not offer an equivalent level of protection to that required in the European Union. You are advised that the United States of America uses a sectoral model of privacy protection that relies on a mix of legislation, governmental regulation, and self-regulation. Article 26 of the European Union’s Data Protection Directive (Directive 95/46/EC, 1995 O.J. (L 281) 31) allows for transfer of Personal Data from the European Union to a third country if the individual has unambiguously given his consent to the transfer of Personal Data, regardless of the third country’s level of protection. By using our Services, you consent to the transfer of all such information to the United States of America which may not offer an equivalent level of protection to that required in the European Union and to the processing of that information by the Company on its servers located in the United States of America as described in this Privacy Policy. 

Changes to Our Privacy Policy 

We reserve the right to make corrections or updates to this Privacy Notice at our discretion from time to time. When we do so, we will post the updated Privacy Notice on our website and update the Privacy Notice’s Effective Date. We will notify you of material changes to this Privacy Notice by placing a prominent notice at the top of the Privacy Notice for thirty (30) days. The date the privacy policy was last revised is identified at the top of the page. Your use our Services after any changes to the Privacy Policy have been posted is your consent and agreement to all of the changes. We encourage you to periodically review this Privacy Notice. 

Contact Information 

If you have any questions or concerns, please feel free to contact our Compliance Department at compliance@tradepmr.com. 

Privacy Notice for California Residents 

This Privacy Notice for California Residents supplements the information contained in our Privacy Policy and applies solely to all visitors, users, and others who reside in the State of California. We adopt this notice to comply with the California Consumer Privacy Act of 2018 (CCPA). This notice does not apply to employment-related Personal Data collected from California-based employees, job applicants, contractors, or similar individuals. 

Your Rights and Choices 

Access

You have the right to request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you (to the extent required by law): 

- The categories of Personal Data we collected about you.
- The categories of sources for the Personal Data we collected about you.
- Our business or commercial purpose for collecting or selling that Personal Data. 
- The categories of third parties with whom we share that Personal Data. 
- The specific pieces of Personal Data we collected about you (also called a data portability request). 

Deletion 

You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete your Personal Data from our records, unless an exception applies. 

Personal Data Sales Opt-Out and Opt-In 

The CCPA defines a “sale” as the disclosure of Personal Data for monetary or other valuable consideration. TradePMR does not offer an opt out from the sale of Personal Data because we do not and have not within at least the last 12 months sold Personal Data that is subject to the CCPA’s sale limitation.  

TradePMR does not offer an opt out from the sale of Personal Data because we do not and have not within at least the last 12 months sold Personal Data that is subject to the CCPA’s sale limitation. 

Exercising Access and Deletion Rights 

To exercise the rights described above, you or your Authorized Agent (defined below) must send us a request that (1) provides sufficient information to allow us to verify that you are the person about whom we have collected Personal Data, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You do not need an account to submit a Valid Request.  

We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive, or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request. 

You may submit a Valid Request via email to our Compliance Department at  compliance@tradepmr.com. 

You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.  

Responding to Requests 

We cannot respond to your request or provide you with Personal Data if we cannot verify your identity or authority to make the request and confirm the Personal Data relates to you. We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.  

Privacy and data protection laws, other than the CCPA, apply to much of the Personal Data that we collect, use, and disclose. When these laws apply, Personal Data may be exempt from, or outside the scope of, Access Requests and Deletion Requests. For example, information subject to certain federal privacy laws, such as the Gramm-Leach-Bliley Act or the Health Insurance Portability and Accountability, is exempt from CCPA Requests. As a result, in some instances, we may decline all or part of an Access Request or Deletion Request related to Personal Data exempt from CCPA Requests. This means that we may not provide some or all of this Personal Data when you make an Access Request. Also, we may not delete some or all of this Personal Data when you make a Deletion Request.  

Non-Discrimination 

We will not discriminate against you for exercising any of your CCPA rights. We will not: 

- Deny you goods or services.
- Charge you different prices or rates for our Services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of service.
- Suggest that you may receive a different price or rate for our Services or a different level or quality. 

TradePMR does not sell your Personal Data; therefore, CCPA-permitted financial incentives are not applicable. 

Changes to Our Privacy Notice for California Residents 

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes. 

Contact Information 

If you have any questions or comments about this notice, the ways in which we collect and uses your information described below [and in the Privacy Policy], your choices and rights regarding such use, or wish to exercise your rights under California law, please feel free to contact our Compliance Department at compliance@tradepmr.com.