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⦁    General. When reasonably practicable, Company shall attempt to respect and maintain User’s privacy. Company shall not monitor, edit, or disclose any personal information about User or User’s account, including its contents or User’s use of the Software, without User’s prior written consent unless Company has a good faith belief that such action is necessary to: (i) comply with any legal process or other legal requirements of any governmental or regulatory authority, (ii) protect and defend the rights, interests, or property of Company, (iii) enforce this Agreement, (iv) protect the interests of users of the Software other than User or any other person, entity, partnership, organization, association or otherwise, or (v) operate or conduct maintenance and repair of Company’s services or equipment, including the Software as authorized by law. User has no expectation of privacy with respect to the Internet in general. User’s IP address is transmitted and recorded with each User session.


⦁    Cookies. The Software may use cookies. A cookie is a small data file that a website stores on the User’s computer when the Software is accessed via the Internet. A cookie allows Company to monitor activity on its website and remember user preferences. Company uses information contained in cookies to improve the User’s experience, as well as track usage and tailor service options and content to usage patterns. Company does not use cookies to retrieve information from the User’s computer not related to the Software.


⦁    Billing/Credit or Charge Card Information. Company shall not share billing/credit or charge card information provided by the User with third parties outside of Company charge card processor vendor used to process transactions unless written or electronic permission is expressly received from User.


⦁    Use of Aggregate Information. Company may, at its sole discretion, share aggregate information (e.g. number of website visits, demographic breakdown, etc.) to third parties by combining aspects of personal information into an anonymous pool.


⦁    Security of Personal Information. Information security is of the utmost importance to Company, however, no transmission of data over the Internet is guaranteed to be completely secure. Company shall not guarantee or warrant the security of any personal information transmitted to or from it. Any such transmission is made solely at User’s risk.


⦁    Links. Company’s Software website may contain links to other Internet websites. If websites are not owned by Company these websites would not be under the control of Company and Company would not control some linked websites’ privacy and/or user agreements. Company does not grant any warranties (express or implied) nor does Company have any liability for information transferred and conferred to or from linked websites.


⦁    Audits. Company may gain access to customers trading activity for auditing purposes. Such records may be disclosed to an independent audit source. Reasonable and industry appropriate non-disclosure agreement(s) shall pertain to third party auditing sources. Software may transmit trade execution data over the Internet to a secure database for the purpose of audit tracking.

User shall be solely responsible for the security, confidentiality and integrity of all messages and the content that User receives, transmits through or stores via the Software or on any computer or related equipment that is used to access the Software. User shall be solely responsible for any authorized or unauthorized access to User’s brokerage account by any person, entity, partnership, organization, association or otherwise.

⦁    Sharing User Information. User authorizes Company to use User’s information in accordance with the Company’s Privacy Policy that can be viewed at:

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