|Category of Personal Information Collected||Source||Purpose for Collection||Categories of Recipients|
|Contact information: such as name and email address||From you when you register for or enroll in the Site or any Client Services (or on your behalf when you are registered or enrolled in connection with an entity or group)||To provide, manage, support, improve and personalize the Site and Client Services and any related transactions, and to communicate with and respond to you about the Site or Client Services, including to validate your identity or to meet legal obligations||Our affiliates, agents and successors; to the extent relevant, select marketing, technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations); and, as applicable, an entity or group under which you are registered or enrolled|
|Forum information: such as information you enter into any forum or other collaborative environment or communication tool available on or through the Site or Client Services||From you when you input information into any such environment or tool||To collaborate and communicate, as contemplated by such environment or tool||Users who are authorized to view or use such environment or tool (or the applicable portion thereof) or to whom such information is communicated or designated; our affiliates, agents and successors; and, to the extent relevant, select technical and other service providers (who perform certain services and functions on our behalf and who are bound by confidentiality obligations)|
|Payment information: such as name, card issuer and card type, credit or debit card number, expiration date, CVV code, and billing address||From you or your payment card issuers||Authorizing of credit card and other financial transactions with respect to your subscription or other payment obligations, as applicable, related to the Site or Client Services||Our service providers who process payments for us—they are prohibited from using personal information for any other purposes and are contractually required to comply with all applicable laws and requirements, which includes the Payment Card Industry Data Security standards|
|Legal process-related information: such as details of your identity, or suspected or alleged criminal, dangerous, impermissible, unlawful or other relevant behavior||From crime and fraud prevention agencies, you, witnesses or law enforcement agencies||To protect users, the public and our business against risks and crime||Law enforcement and other governmental authorities in accordance with applicable law, our technical and other service providers, and our professional advisors|
TradeWing will only use personal information to the extent it is reasonably necessary to deliver, manage, support, improve or personalize the Client Services or the Site. In some jurisdictions, individuals may have the right to withdraw consent from certain uses. If you reside in such jurisdictions, you may have additional rights which are detailed in sections 8 through 10. In all cases, any service providers will be contractually limited in the way they may use personal information maintained by TradeWing, including requirements that such information be maintained in a confidential and secure manner.
In Connection with Business Transfers: In the event that a division, a product or all of TradeWing is bought, sold or otherwise transferred, or is in the process of a potential transaction, personal information will likely be shared for evaluation purposes and included among the transferred business assets, subject to client contractual requirements and applicable law.
To Comply with Laws: TradeWing may also disclose specific personal information when such disclosure appears necessary to comply with applicable law, a subpoena in the course of managing a dispute, governmental inquiry or other litigation process. We may also disclose information to our accountants, auditors, agents, lawyers and other advisors in connection with the enforcement or protection of our legal rights or to protect the interests or safety of our users or others, in accordance with or as authorized by law.
A cookie is a small piece of information that a website, online application, or email may save to your browser or your computer’s hard drive for use in subsequent visits to the website or online application. The “help” portion of the toolbar on most browsers will tell you how to prevent your browser from accepting new cookies, how to have the browser notify you when you receive new cookies or how to disable cookies altogether. If you reject cookies, you may not be able to participate in certain activities or receive a promotion tailored to you. TradeWing does not control and does not guarantee the effectiveness of browser-based tools for managing cookies.
TradeWing does not currently participate in interest-based or behavioral online advertising, and information automatically collected from the Site is not used by TradeWing for that purpose.
TradeWing may use Google Analytics to evaluate use of the Site for our internal purposes such as evaluating usages of the Site. To learn how Google Analytics collects and processes data, please visit: “How Google uses data when you use our partners’ sites or apps” located at www.google.com/policies/privacy/partners.
Do Not Track (DNT): This is a privacy preference that users can set in some web browsers, allowing users to opt out of tracking by websites and online services. At the present time, the World Wide Web Consortium, or W3C, has not yet established universal standards for recognizable DNT signals, and therefore TradeWing and the Site do not recognize DNT.
Where applicable, TradeWing uses industry-standard technology in connection with the Client Services and the Site to help protect personal information from loss, misuse and unauthorized access, disclosure, alteration and destruction.
Personal information that we collect, access or process will be retained only as long as necessary for the fulfilment of the purposes for which it was collected, unless otherwise provided for under services contracts with clients or as required or authorized by law. Personal information that is no longer required to fulfil the identified purposes will be destroyed, erased or de-identified.
Our clients are responsible for notification of purpose and for obtaining appropriate consent, to the extent required by law, when they collect personal information that is transferred to TradeWing.
Our clients are responsible for ensuring that any commercial emails sent by them comply with applicable law. If we are instructed by our clients to transmit communications on their behalf, clients remain responsible for ensuring that recipients have consented to receiving such communications and that the information contained in the communications are accurate and complete.
We do not sell, rent, or share the personal information of our users with third parties for such third parties’ own marketing purposes.
TradeWing may, subject to applicable laws, use personal information from our users to contact them about the Site and Client Services, including to provide them with information on additional products from TradeWing that may be of interest to them. Our users may exercise choices regarding these communications as follows:
TradeWing and the Site and Client Services are not directed toward children and we do not knowingly solicit or collect personal information online from children under the age of 13 without prior verifiable parental consent. If TradeWing learns that a child under the age of 13 has submitted personal information online without parental consent, we will take all reasonable measures to delete such information from our databases and to not use such information for any purpose (except where necessary to protect the safety of the child or others as required or allowed by law). If you become aware of any personal information we have collected from children under age 13, please contact us using the information detailed in the Contacting Us section below.
In certain jurisdictions, you may have the right to obtain confirmation as to whether your personal information is being processed, information about the purposes of that processing, and information about the recipients to whom your personal data have been or will be disclosed. You may also have the right to receive a copy of the personal data you have provided and/or request its deletion.
Our clients are responsible for managing any request made by their users regarding access to and rectification of their personal information that is transferred to us. However, if you have questions about your rights, please feel free to contact using the contact information detailed in the Contacting Us section below.
If you are a California resident, California law provides you with the following rights with respect to your personal information:
When you exercise these rights and submit a request to us, we may verify your identity. We also may use a third party verification provider to verify your identity. Your exercise of these rights will have no adverse effect on the price and quality of our goods or services.
In some cases, personal information that we process, including information from our users located in various countries, including in Canada, the EU and Switzerland or relative to queries or visitors to the Site may be transferred to the United States or other countries that may not have data privacy laws that provide the same protection as the countries where you reside. You understand that your personal information may therefore be transferred, processed and stored outside of your country of residence, and therefore may be available to government authorities under lawful orders and laws applicable in such foreign jurisdictions.
We are transparent about the ways in which we collect and use personal information, and welcome your questions and concerns. If you have any concern or complaint about the way we handle your personal information, please contact us as described below. To the extent you believe we have not addressed your concerns or otherwise choose to do so, you have the right to lodge a complaint with a supervisory authority in the country where you reside and/or in the United States. For information on how you can file a privacy complaint with the Federal Trade Commission, please visit: https://www.ftccomplaintassistant.gov/
Attn: Eric Meisel CEO
48 Grattan Street
San Francisco, CA 94117