Privacy Policy

Effective Date: January 1, 2021

Last Updated: December 31, 2020

tradingvivo, Inc. (collectively, «tradingvivo», «we», «us», «our»), is committed to protecting your privacy, including your personal information (as defined in Section 1.1 below).

This Privacy Policy governs our practices for the collection, processing and use of Personal Information with respect to our Website and Subscription Services (each as defined in Section 1.2 below under «Websites» and «Subscription Services») . It also describes your choices regarding the use, access, and correction of your personal information. By using the Website or Subscription Services, you consent to the personal information processing practices described in this Privacy Policy. If you do not agree to the personal information processing practices described in this Privacy Policy, you should not use the Website or the Subscription Services.

  1. Definitions

1.1. «Personal information»

This refers to any information that personally identifies you, directly or indirectly, including contact information such as your name, email address, aliases, company name, physical and postal address, telephone number, IP address, details. credit card and other information about you. or your home. Personal information may also include information about any transactions, both free and paid, that you make on the websites.

1.2. «Website» and «Subscription Services»

This Privacy Policy applies to our website (www.tradingvivo.com), as well as any other site owned and operated by us and related processing activities on our behalf by third parties, for example, in order to perform online marketing, payment processing, customer service, as well as other types of services, as described below. The Privacy Policy also applies to our tradingvivo training and tradingvivo business Subscription Services offered through our Website (the «Subscription Services»), including associated mobile applications (Mobile Applications) owned and controlled by tradingvivo.

  1. Changes and updates

We periodically update this Privacy Policy. Any changes will be effective as of the time the new Privacy Policy is posted, as indicated by the «Effective Date» above.

Your use of the Website or Subscription Services after changes to this Privacy Policy have been implemented constitutes your acknowledgment and acceptance of the new Privacy Policy. If you do not agree to the terms of the new Privacy Policy, you should no longer use our Website or the Subscription Services.

  1. Questions and concerns

If you have any questions about this Privacy Policy, please contact our Data Protection Officer at privacy@tradingvivo.com or by mail at:

tradingvivo, Inc.

For the attention of: Dr. Patricia Pizzolato, data protection officer

J.E. Irauquin 232B

Oranjestad, AW 00

Aruba

You can also use these contact details to exercise your privacy rights. In addition, you may be able to submit a request to exercise your privacy rights by completing a web form available on the website.

  1. Information We Collect and How We Use It

4.1. Information that you voluntarily provide when you visit our website and use our subscription services

You are free to explore our website without providing any personal information about yourself. You may also voluntarily provide us with personal information when you sign up to receive additional information from our website, or register and use one of our subscription services, contact our customer service team, send an email, post a comment on our Blog. , or communicate with us in any other way. The personal information we process may include your name, address, email address, telephone number, credit card information, and professional information. Additionally, custom fields can capture any other type of personal information that you choose to share with us.

Our online subscription services allow you to create trading plans, analyze stock data, and manage email and other electronic communications.

Users of our Subscription Services may store any type of Personal Information in the services, including content and files attached to emails, as well as Personal Information related to their Google account («Google User Data») . However, tradingvivo does not have access to or share any of that data and does not know what type of data you or other users are storing. The data is only used by the account owner and invited end users when they intend to use it.

Additional limits on the use of your Google user data: Without prejudice to anything else in this Privacy Policy, if you provide access to the following types of Google user data as part of the use of our Subscription Services, our use of that data will be subject to these restrictions:

We will only use access to read, write, modify or control the body of Gmail messages (including attachments), metadata, headers and settings to provide a web email client that allows users to compose, send , read and process emails, transfer this data from Gmail to others unless it is necessary to provide and improve these functions, comply with applicable law or as part of a merger, acquisition or sale of assets.

We will not use this Gmail data to serve ads.

We will not allow humans to read this data unless: (i) we have your affirmative consent for specific messages, (ii) doing so is necessary for security reasons, such as investigating abuse, (iii) to comply with applicable law, or ( iv)) for our internal operations and even then only when the data has been aggregated and anonymized.

Please see Section 5.4 below titled “Use of Personal Information” to understand how we use the personal information that you voluntarily provide when you visit our website and use our subscription services. We may share your personal information with third parties, as necessary, solely to enable them to perform those specific services for us. Said third parties include those:

  • help us send marketing emails,
  • provision of cloud storage services;
  • provision of customer support services;
  • allowing us to send you emails;
  • provision of subscription management services, integration of payment and billing gateways;
  • provision of problem tracking software;
  • allow payment processing;
  • offer marketing and advertising services;
  • help schedule appointments;
  • provision of online survey software;
  • provision of website and application analytics services
  • Provision of web conferencing services; Y
  • provision of subscription income analysis services.

Such third parties are prohibited from using your personal information except for these purposes, and they are required to maintain the confidentiality and security of your information.

4.2. Payment and order information

We collect and process your payment information when you subscribe to any of our Subscription Services or request any product or service from our Website, including credit card numbers, billing information, and shipping information using third-party service providers that comply. with PCI that provide subscription management. , integration of payment gateways and billing services. Such third parties are prohibited from using your personal information except for these purposes, and they are required to maintain the confidentiality and security of your information.

We use this information to complete the billing and payment processes for your use of our Subscription Services or in connection with the orders you have placed on our Website.

4.3. Information We Collect Automatically

When you use any of our Subscription Services or browse our Website, we or our third-party service providers may collect information about your visit to our Website, your use of the Subscription Services, and your web browsing. That information may include your IP address, your operating system, your browser identification, your browsing activity, and other information about how you interacted with our website. We may collect this information as part of the log files, as well as through the use of cookies or other tracking technologies. Our use of cookies and other tracking technologies is discussed in more detail in Section 4.6 below, and in more detail in our Cookie Agreement. Please see Section 5.4 below titled “Use of Personal Information” to understand how we use the personal information that you voluntarily provide when you visit our websites and use our subscription services. We may use third parties to perform certain services on our behalf. We may share your personal information with these third parties, as necessary, solely to enable them to perform those specific services for us. Said third parties include those:

  • help us send marketing emails and track social media;
  • provision of cloud storage services;
  • allow payment processing;
  • bug tracking on web platforms;
  • provision of problem tracking software;
  • provision of video transmission services;
  • provision of email automation, performance tracking and web analytics software; Y
  • provide customer support services.

Such third parties are prohibited from using your personal information except for these purposes, and they are required to maintain the confidentiality and security of your information.

4.4. Information about your use of our subscription services

We may receive information about how and when you use the Subscription Services and store that information in log files or other types of files associated with your account, and link it to other information that we collect about you. This information may include, for example, your IP address, time, date, browser used, and actions you have taken within the Subscription Service. This type of information helps us improve our Subscription Services for both you and all of our users. We may use third parties to perform certain services on our behalf. We may share your personal information with these third parties, as necessary, solely to enable them to perform those specific services for us. Said third parties include those:

  • provision of cloud storage services;
  • provision of customer support services;
  • provision of email automation, performance tracking and web analytics software;
  • provision of subscription management services, integration of payment and billing gateways; Y
  • provision of video transmission services;
  • provision of problem tracking software;
  • bug tracking on web platforms;
  • offering marketing and advertising services.
  • help us send marketing emails and track social media;
  • serve advertisements; Y
  • allowing us to send you emails.

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4.5. Information we receive from third parties

We may also receive your Personal Information directly from third parties, such as users of our Subscription Services who may provide us with their Personal Information directly. For example, the account holder provides us with the email address of other end users so that we can send them an invitation to join the live trading ecosystem. Please see Section 5.4 below titled “Use of Personal Information” to understand how we use the personal information we receive from third parties.

4.6. cookies

tradingvivo and its third-party partners use cookies or similar technologies to analyze trends, administer our website, track user movements on our website, and collect demographic information about our user base as a whole.

We use «cookies» to help you personalize your online experience. A cookie is a text file that a web server places on your hard drive. Cookies are not used to run programs or deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a web server in the domain that issued the cookie to you. One of the main purposes of cookies is to provide a convenient function to save you time. The purpose of a cookie is to tell the web server that you have returned to a specific page. For example, if you personalize pages on our website or register for the Subscription Service, a cookie helps us remember your specific information on subsequent visits. When you return to the same website, the information you previously provided can be retrieved, so that you can easily use the custom functions.

tradingvivo keeps track of the websites and pages you visit within the tradingvivo network of sites and services, to determine which part of the website or subscription service is the most popular or the most used. This data is used to deliver personalized content and promotions within the tradingvivo website and subscription services to clients whose behavior indicates that they are interested in a particular subject area.

tradingvivo also uses cookies and similar tracking technologies to deliver targeted advertisements. In addition, we partner with third parties to display advertising on our website or to manage and serve our advertising on other sites. Our third-party partners may use cookies or similar tracking technologies to serve you advertising or other content based on your browsing activities and interests. Our third-party advertising partners include Google Ads, Microsoft Ads, Facebook, LinkedIn, GetApp, Software Advice, Capterra, and G2.

If you do not want this information to be used for the purpose of serving you targeted advertisements, you can opt out of certain companies that serve you targeted advertisements by clicking here: http://preferences.truste.com/, or if you are on the European Union, by clicking here: http://www.youronlinechoices.eu/. Please note that this does not exclude you from receiving advertising. You will continue to receive generic ads.

You have the ability to accept or reject cookies. Most web browsers accept cookies automatically, but you can usually modify your browser settings to reject cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the Subscription Services or the Websites that you visit. Please note that we have automatically disabled cookies that are strictly necessary for the use of subscription services and the website. When you choose to use cookies, you ask us to disclose certain personal information to third parties who place cookies on our websites. To learn more about our use of cookies and other tracking technologies, as well as how to opt out of the use of cookies, please visit our Cookie Agreement.

4.7. Delete Gifs, Web Beacons and Web Bugs

We employ a software technology called clear gifs (also known as Web Beacons / Web Bugs), which helps us better manage the website and subscription services by informing us what content is effective. Clear gifs are tiny graphics with a unique identifier, similar in function to cookies, and are used to track the online movements of Web users. Unlike cookies, which are stored on the user’s computer hard drive, clear gifs are embedded invisibly on web pages or in emails and are roughly the size of the period at the end of this sentence. We use clear gifs in our HTML-based emails to inform us which emails have been opened by recipients. This allows us to measure the effectiveness of certain communications and the effectiveness of our marketing campaigns. We link the information collected by clear gifs in emails to our customers’ personal information. If you wish to opt out of receiving these emails, please see «Right to Unsubscribe from Marketing Communications» below.

We may use third parties to perform certain services on our behalf. We may share your personal information with these third parties, as necessary, solely to enable them to perform those specific services for us. Said third parties include those:

  • offering marketing and advertising services.
  • help us send marketing emails and track social media;
  • serve advertisements; Y
  • allowing us to send you emails.

4.8. Single sign-on

You can log into our Subscription Services using a single sign-on (SSO) service such as your Google account. This service will authenticate your identity and provide you with the option to share certain Personal Information with us, such as your name and email address, in order to pre-complete our registration form. Such services may give you the option to post information about your activities on this website on your profile page to share with others within your network. This information is shared with the SSO provider, such as Google.

4.9. Personal information about children

The Website and Subscription Services are not intended for or directed at children under the age of thirteen (13), and we do not knowingly or intentionally collect or disclose Personal Information about children under the age of thirteen (13). If you believe that we have collected personal information about a child under the age of thirteen (13), please contact us as indicated above in the section titled «Questions and Concerns» so that we may delete that personal information.

  1. How we use the personal information we collect

5.1. Comtroller

Within the scope of this Privacy Policy, we act as a data controller (or a CCPA regulated company) («data controller») or a data processor (or a CCPA service provider) («data processor» ) for Personal Information we process, depending on our relationship with you. For example, if tradingvivo processes your personal information in the course of providing subscription services, tradingvivo acts as a data processor for your personal information that we process. Rather, tradingvivo is a data controller of your personal information that we process in connection with our marketing and other front-end activities on our website.

5.2. Processing base

When we act as a data controller within the scope of this Privacy Policy, we may rely on one or more of the following legal grounds for the processing of your Personal Information:

  • Your consent;
  • fulfill our obligations under a contract to which you are a party or perform the steps requested by you before entering into a contract;
  • pursue our legitimate interests, such as our interest in marketing our services; Y
  • for any other reason, as required or permitted by law.

Where we rely on your consent as a legal basis for processing your personal information, you can withdraw your consent at any time. However, if you withdraw your consent, it will not affect the lawfulness of the processing that occurred based on your consent prior to its withdrawal.

When we act as a data processor within the scope of this Privacy Policy, we will process your personal information according to the documented instructions of the relevant data controllers.

When we act as a data controller and receive your Personal Information directly from you in order to provide you with our Subscription Services or other services related to our Website, we require such Personal Information in order to fulfill our contractual obligations to you. Without the necessary personal information, tradingvivo will not be able to meet your requests

5.3. We never sell personal information

We understand how important your personal information is to you. We are committed to keeping it strictly confidential. Your privacy is not for sale. We will never sell, rent or abuse the Personal Information you have entrusted to us. We also confirm that we have not sold personal information to third parties for commercial or commercial purposes in the preceding twelve (12) months and that we have not disclosed personal information to third parties, except as described in this Privacy Policy.

Our website and Subscription Services use third-party cookies. However, cookies that are not strictly necessary are automatically disabled for US users. You can learn more about our use of cookies by reading Section 4.6 entitled «Cookies» in this Privacy Policy, as well as our Cookie Agreement.

5.4. Use of personal information

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to: (a) improve your browsing experience by personalizing the Website and to improve the Subscription Services; (b) send you information that we think may be of interest to you by post, email or other means; (c) send you marketing communications related to our business or the businesses of carefully selected third parties that we think may be of interest to you, and (d) provide other companies with anonymous statistical information about our users, but this information will not be used to identify to any individual user.

From time to time, we may communicate with you on behalf of third-party business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your unique personal information to third parties

5.5. Advertising

We partner with third-party ad networks to display advertising on our websites or to manage our advertising on other sites. Our ad network partners (including Google Ads, Microsoft Ads, Facebook, LinkedIn, GetApp, Software Advice, Capterra, and G2) use cookies and web beacons to collect non-personally identifiable information about your activities on this and other websites to provide you with specific advertising information based on your interests. If you do not want certain companies to use this information in order to serve you targeted advertisements, you can opt out by clicking here: http://preferences.truste.com/ (or if you are located in the European Union, by clicking here : http://www.youronlinechoices.eu/). Please note that this does not exclude you from receiving advertising. You will continue to receive generic ads.

5.6. Customer testimonials and comments

We post customer testimonials and comments on our website, which may contain personal information, in order to market our products and services. If you would like your testimonial or comments to be modified or removed from our website, please contact us as requested in the section above titled «Questions and Concerns.»

5.7. Use of credit card information

If you provide us with credit card information, we use it only to verify your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain or use the information you provide, except for the sole purpose of processing the credit card on our behalf.

5.8. Social media features

Our website includes social media features such as the «Like» button and Facebook widgets and interactive mini-programs that run on our site. These features may collect your IP address, what page you are visiting on our site, and may set a cookie to allow the feature to function properly. Social media functions and widgets are hosted by a third party or directly on our website. The way these third parties process your personal information is governed by the privacy policies and other policies of the companies that provide them.

5.9. External websites

Our website provide links to other websites. We do not control and are not responsible for the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy policy and other policies that they may have.

5.10. Public forums

We offer publicly accessible message boards, blogs, and community forums for you to share your ideas and improve our website and subscription services. Please note that if you directly disclose any information through our forums, blogs, or public message boards, this information may be collected and used by others. We will correct or delete any personal information that you have posted on the website upon request, as described in the section entitled «Your privacy rights» below

5.11. Retention of personal information

When we act as a data processor, we retain your personal information for as long as is necessary for us to fulfill our commitment to the data controller.

When we act as a data controller, we retain the Personal Information you provide to us as long as we consider it potentially useful for communicating with you about the Subscription Services or our services, or as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements, and then we securely erase that Personal Information, but in any event within a period of no more than 12 months after the purposes of the processing are fulfilled. We may remove this information from servers at an earlier date if requested, as described in the section titled «Your Privacy Rights» below.

5.12. International transfer of personal information

Some of the third parties that receive your personal information may be located in countries outside the European Union or the European Economic Area («EEA»). In some cases, the European Commission may not have determined that the legal environment in those countries provides a level of data protection that is essentially equivalent to the level of protection provided by European Union law. You can see here the list of countries that the European Commission has recognized as providing an adequate level of protection for personal information. We will only transfer your personal information to third parties in countries that are not recognized as providing an adequate level of protection to personal information when appropriate security measures are in place. These may include standard data protection contractual clauses approved by the European Commission under article 46.2 of the GDPR, or transfers based on the Privacy Shield framework.

5.13. Corporate events

If we (or our assets) are acquired by another company, whether by merger, acquisition, bankruptcy or otherwise, that company would receive all information collected by tradingvivo on the Website and Subscription Services. In this case, you will be notified by email and / or a prominent notice on our website, of any changes in ownership, uses of your personal information, and choices you may have regarding your personal information.

5.14. Mandatory disclosure

We reserve the right to use or disclose your personal information if required to do so by law or if we reasonably believe that the use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or comply with a law, court order or legal process.

  1. Security

6.1. Security of your personal information

We use a variety of security technologies and procedures to help protect your personal information from unauthorized access, use, or disclosure. We secure the personal information you provide on computer servers in a controlled and secure environment, protected from unauthorized access, use or disclosure. When sensitive personal information (such as a credit card number and / or geographic location data) is collected on our website and / or transmitted to other websites, it is protected through the use of encryption, such as the secure socket layer. (SSL) protocol.

6.2. Alerts in case of security breach

If a security breach causes an unauthorized intrusion into our system that materially affects you, then tradingvivo will notify you as soon as possible and then report the action we take in response.

  1. Your privacy rights

If you are a data subject about whom we process personal information, you may have specific rights with respect to that information. Please note that you can only exercise these rights with respect to the Personal Information that we process about you when we are acting as a data controller (that is, when we decide why and how your Personal Information will be processed, and not our customers). To exercise your rights with respect to information processed by us on behalf of one of our clients, please read our client’s Privacy Policy.

7.1. Your privacy rights

In this section, we first describe your privacy rights and then explain how you can exercise those rights.

7.1.1. Right to know what happens to your personal information

This is called the “right to be informed”. It means that you have the right to obtain from us all information about our data processing activities that concern you, such as how we collect and use your personal information, how long we will keep it and with whom it will be shared, among other things. .

We inform you how we process your personal information with this Privacy Policy.

We will always try to inform you about how we process your personal information. However, if we do not collect Personal Information directly from you, the GDPR exempts us from the obligation to inform you (i) when providing the information is impossible or excessively costly; (ii) the collection and / or transmission is required by law, or if (iii) the Personal Information must remain confidential due to professional secrecy or other legal secrecy obligations.

7.1.2. Right to know what personal information we have about you

This is called the right of access. This right allows you to request full details of the personal information we hold about you.

You have the right to obtain from us confirmation as to whether or not we process the Personal Information concerning you and, if so, request a copy or access to the Personal Information and certain related information.

Please note that the CCPA does not allow us to disclose Social Security numbers, driver’s license numbers or other government-issued identification numbers, financial account numbers, medical or health insurance identification numbers, account passwords or questions and security responses. We may inform you that we have this information in general, but we may not provide you with specific numbers, passwords, etc. for legal and security reasons.

Please note that you can only submit two access requests in a twelve month period.

7.1.3. Right to change your personal information

This is called the right of rectification. You have the right to ask us to correct without undue delay anything you believe to be incorrect or out of date with the Personal Information we have on file about you, and to complete any incomplete Personal Information.

If your account settings do not allow you to change your account, please contact us and we will do our best to change your personal information for you.

7.1.4. Right to request that we delete your personal information from our records

This is called the right to erase, the right to erase, or the «right to be forgotten.» This right means that you can ask us to delete your personal information in certain circumstances. Sometimes we may remove your information, but other times it is simply not possible, such as when the law tells us that we cannot. If that’s the case, we’ll consider whether we can limit how we use it.

7.1.5. Right to request us to change the way we process your personal information

This is called the right to restrict processing. It is the right to ask us to use or store your personal information only for certain purposes. You have this right on certain occasions, such as when you believe that the data is inaccurate

7.1.7. Right to transfer or transfer your personal information

This is called the right to data portability. It is the right to request and download personal information about you that you have provided to us or that you have generated by virtue of the use of our services, so that you can:

  • Move it;
  • Copy it;
  • Keep it to yourself; or
  • Transfer it to another organization.

We will provide you with personal information in a structured, commonly used and machine-readable format. When you electronically request to know what data we hold about you, we will provide you with a copy in electronic form.

7.1.8. Right to unsubscribe from marketing communications

You can unsubscribe from our marketing communications by clicking the «unsubscribe» link at the bottom of our emails, or by contacting us as outlined in the «Questions and concerns» section above. Customers cannot opt ​​out of receiving transactional emails, such as billing notifications related to their account with us or the Subscription Services.

7.1.9. Law related to automated decision making

We sometimes use computers to study your personal information. We may use this personal information to find out how you use our services. For decisions that may seriously affect you, you have the «right not to be subject to automatic decision-making, including profiling.» But in those cases, we will always explain to you when we could do this, why it is happening, and the effect.

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7.1.10. Right to withdraw your consent

Where we rely on your consent as a legal basis for processing your personal information, you can withdraw your consent at any time. If you withdraw your consent, our use of your Personal Information before we withdraw it remains legal.

If you have given your consent for your data to be shared with a third party and wish to withdraw this consent, please also contact the relevant third party to change your preferences.

7.1.11. Right not to be discriminated against for exercising your privacy rights

We will not discriminate against you for exercising any of your privacy rights. Unless applicable data protection laws allow it, do not:

  • Deny you goods or services;
  • Charge you different prices or fees for goods or services, including by granting discounts or other benefits, or imposing penalties;
  • Provide you with a different level or quality of goods or services; or
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

7.1.12. Right to lodge a complaint with a supervisory authority

If the GDPR applies to the processing of your personal information with us, the GDPR allows individuals to lodge a complaint with a supervisory authority if they are not satisfied with the way we process their personal information.

In particular, you can file a claim in the Member State of the European Union of your habitual residence, place of work or of an alleged infringement of the GDPR.

7.2. How can you exercise your privacy rights?

When we act as a data controller, to exercise any of these rights, please contact us, as indicated in the Section above titled «Questions and Concerns.» We will respond to your request within 30 days and notify you of the action we have taken. If we need more time (up to 90 days total), we will inform you of the reason and the extension period in writing. If you have an account with us, we will send our written response to that account. If you do not have an account with us, we will send you our written response by mail or electronically, at your option.

Please note that we have the right to verify your identity (or the identity of your authorized agent) by whatever means we deem reasonable and appropriate in the circumstances, as described in the Section below titled «Verifying Your Identity.»

If we are unable to satisfy a request, we will also explain the reason in our response. We promise not to charge a fee to process or respond to your requests. The only situations in which we may charge a fee is when we determine that your request is excessive, repetitive, or manifestly unfounded. In those cases, we will tell you why we made that determination and provide you with a cost estimate before completing your request.

When we are acting as a data processor, you can exercise your rights under this Section by contacting the data controller who has provided us with your Personal Information.

7.2.1. Authorized Agents

You can designate an authorized agent to exercise your rights on your behalf. You must designate such agent by written permission or power of attorney pursuant to sections 4000 to 4465 of the Probate Code.

To verify that your authorized agent is acting on your behalf, we will request this permission in writing from your agent or the proxy. In case you have provided your authorized agent with written permission, we will ask you to verify your identity as well.

7.2.2. Verification of your identity

To evaluate your requests for your personal information, we must be sure that it was you who made the request. In some cases, we will ask you to confirm your identity by email. We will only use the Personal Information that you provide to us in a request to verify your identity or authority to make the request. For more sensitive requests, we will ask you to provide us with certain information that we already have about you.

We will only use the personal information you provide us in a request to verify the identity or authority of the requestor to make the request.

  1. EU-US. US and Swiss-American Privacy Shield

tradingvivo complies with the EU-US. Privacy Shield Framework and Swiss-US. Privacy Shield Frameworks (Privacy Shield) as established by the US Department of Commerce with respect to the collection, use and retention of personal information transferred from the European Union and the United Kingdom and / or Switzerland to the United States in accordance with the Privacy Shield. If there is any conflict between the terms of this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles will prevail. For more information on the Privacy Shield program, visit https://www.privacyshield.gov/.

tradingvivo is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC) with respect to the Privacy Shield frameworks.

According to the EU-US. USA and Switzerland-USA Privacy Shield Principles, tradingvivo is committed to resolving complaints about your privacy and our collection or use of your personal information.

Individuals whose personal information is processed within the scope of the Privacy Shield frameworks, and who have inquiries or complaints regarding this Privacy Policy, are advised to first contact us as provided in the Section above titled » Questions and concerns «.

tradingvivo has also agreed to address unresolved privacy complaints under the EU-US. USA and Switzerland-USA Privacy Shield Principles to an independent dispute resolution mechanism. JAMS is the independent US-based organization responsible for reviewing and resolving complaints about compliance with our Privacy Shield, at no charge to you. If you are not satisfied with our initial response, please contact JAMS at www.jamsadr.com/eu-us-privacy-shield. In the event that JAMS still does not address your concern, you may be entitled to binding arbitration under the Privacy Shield and its principles, in accordance with the Privacy Shield Principle of Remedy, Enforcement and Accountability and Annex I of the Shield of privacy.

With respect to the personal information that tradingvivo receives in accordance with the privacy protection frameworks, you have the right to opt out that your personal information is not shared with third parties and to revoke your consent that you have previously provided for your personal information. shared with third parties, except as required by law. You also have the right to opt out if your Personal Information is used for any purpose that is materially different, but compatible with the purpose (s) for which it was originally collected or subsequently authorized by you.

tradingvivo is responsible for processing the personal information it receives, under privacy protection frameworks, and subsequently transfers it to a third party acting as an agent on its behalf. tradingvivo complies with the Privacy Shield Principles for all subsequent transfers of Personal Information. tradingvivo remains responsible for the protection of your personal information that we transfer to our service providers, except to the extent that we are not responsible for the event that results in unauthorized or inappropriate processing

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