By sharing the Privacy Policy for Tradescal LLC and its Companies (collectively, “we” or “us”), we hope to help you understand how information can create new opportunities for you, our customer, as well as to reassure you that we respect and honor customer requests to restrict and protect personal information.

This Statement of Privacy applies to all Tradescal LLC entities and affiliated companies. For the purposes of this Privacy Policy, unless otherwise noted, all references to Tradescal LLC include www.tradescal.com. This also includes any and all related domains that have been created and are operated by Tradescal LLC but does not include web pages created by affiliates participating in the Infinite Wealth promotion.

We will comply with our Canadian Privacy Policy in our communications with all customers who are Canadian residents. If you reside in the EU, please see Your rights under EU Data protection Laws below.

WHY WE COLLECT PERSONAL INFORMATION

Tradescal LLC collects personal information to improve the manner by which we operate, offer our products and services, communicate with you about those products and services, and provide effective, timely customer support when needed. We will never rent or sell any of the personal information we collect from you to third parties, and we do not share your personal information except as set forth in this Privacy Policy.

THE KIND OF PERSONAL INFORMATION DO WE COLLECT

Tradescal LLC collects personal information in a variety of ways when you interact with Tradescal LLC, including when you register or create an account with Tradescal LLC; when you place an order at Tradescal LLC; when you use Tradescal LLC products or services; when you visit Tradescal LLC pages or pages of certain Tradescal LLC partners; when you enter promotions or sweepstakes; when you subscribe to a newsletter or desire to be added to our mailing lists for other products or services; when you correspond or otherwise interact with us; and when you provide feedback in any of our online surveys.

Information we collect may include: your name, e-mail address, phone number, address, product preference information, billing information, demographic information provided by you (such as language, gender, and age, and, if applicable, content preferences and personalization information) and personal interest information. On occasion, we may ask for additional information to enable us to provide you with access to and use of certain information, materials, and services. Tradescal LLC may combine information about you that we have the information we obtain from business partners or other companies.

COOKIES AND HOW DO WE USE THEM

Cookies are small data files that write to your hard drive for record-keeping purposes when you visit a website. Cookies allow Tradescal LLC to measure traffic activity as well as to improve your user experience, for example by remembering your passwords and viewing preferences. Like other major websites,Tradescal LLC uses cookies to provide you with a tailored experience when visiting Tradescal LLC and using our major products. We treat any personal information that may be contained in cookies with the same level of confidentiality as other information you provide to us. If you wish to disable cookie functionality, you may do so by changing the security settings on your browser. However, portions of Tradescal LLC may not function or function as efficiently, without them.

INFORMATION COLLECTED FROM OTHER SOURCES

Social Media Widgets:

The Websites include social media features, such as the Facebook “Like” button, and widgets, such as the “Share This button” or interactive mini-programs that run on our Websites. These features may collect your Internet protocol address, which page you are visiting on the Websites, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Websites. Your interactions with these features are governed by the privacy statement of the companies that provide them.

Information From Third Party Services:

We may also obtain other information, including personal information, from third parties and combine that with information we collect through our Websites. For example, we may have access to certain information from a third-party social media or authentication service if you log into our Services through such a service or otherwise provide us with access to information from the service. Any access that we may have to such information from a third-party social media or authentication service is in accordance with the authorization procedures determined by that service. If you authorize us to connect with a third-party service, we will access and store your name, email address(es), current city, profile picture URL, and other personal information that the third-party service makes available to us, and use and disclose it in accordance with this Policy. You should check your privacy settings on these third-party services to understand and change the information sent to us through these services. For example, you can log in to the Services using single sign-in services such as Facebook Connect or an Open ID provider.

These single sign-on services will authenticate your identity, provide you with the option to share certain personal information (such as your name and email address) with us, and pre-populate our sign-up form. Services like Facebook Connect give you the option to post information about your activities in the Services to your profile page to share with others within your network.

ACCOUNT DATA

Account data (“Account Data”) is personal information you provide us, or that we collect from you and your devices in connection with your access to and use of our Services (such as when you provide us information to register for an account, or information we collect about your browser when you connect to one of our Services, etc.). In legal terms, we collect and use this Account Data as a data controller. There are two general categories of Account Data we collect in order to provide you with the Services.

THE INFORMATION YOU GIVE US

Account information. You may provide us with information in connection with the creation and management of your account for the Services, such as a name, email address, and a password to create an account.

Billing information. If you have purchased a paid version of the Services, or if you make another financial transaction using our Services (such as purchasing a Third-Party App), we (and our third-party payment processors) will collect information about the purchase or transaction. This includes billing details and credit card information, other account, and authentication information.

Other information. You may otherwise choose to provide us with information when you fill in a form, contact our customer support, respond to surveys, or use other features of our Services. You may also provide us with other optional information as part of your account profile, including your usernames, avatars, and links to the Social Network profiles you authenticate with your account.

INFORMATION WE AUTOMATICALLY COLLECT FROM YOUR USE OF THE SERVICES

Log data and usage information. Like most websites, when you view content on or otherwise interact with our Services our servers automatically record information, including information that your browser sends whenever you visit a Website or that your Application sends when you are using it. This log data may include your IP address, the address of the web page you visited before using the Services, your browser type and settings, your device information, the date and time of your use of the Services, information about your browser configuration and plug-ins, language preferences, unique identifiers, mouse tracks, and cookie data. Location information. When you use our Services, we may collect information about your geographic location.

ACCOUNT DATA – HOW WE USE IT

We use, store, and process Account Data as a data controller to provide, understand, improve and develop our Services, keep our Services safe and to comply with our legal obligations. More particularly, we use it to:

IDENTIFY OUR USERS

We use Account Data to identify you when you log in to your account.

PROVIDE SERVICES

We use Account Data to enable us to operate the Services and provide them to you, including to:

Enable your access to our Services

Allow you to communicate with us and with other users

Verify your transactions, for purchase confirmation, billing, security, and authentication (including security tokens for communication with installed Third-Party Apps)

Contact you about your account and provide customer service support, including responding to your comments and questions

Keep you informed about the Services, features, surveys, newsletters, offers, contests, and events we think you may find useful or which you have requested from us

Sell or market our products and Services to you

IMPROVE AND OPTIMIZE OUR SERVICES

We use Account Data to:

Better understand your needs and the needs of users in the aggregate, diagnose problems, analyze trends, perform analytics, conduct research and improve the features and usability of the Services, test and troubleshoot new products, and better understand and market to our users

Analyze the Website or the other Services and information about our visitors and users, including research into our user demographics and user behavior.

Create aggregate (non-identifiable) statistics about users of the Services with a view to introducing improvements and improving the usability of the Services

KEEP OUR SERVICES SAFE

We use Account Data to verify accounts and activity, maintain the integrity of our Services, and to keep the Services safe and secure.

ACCOUNT DATA – LEGAL BASIS FOR USE

Our legal basis for collecting and using Account Data as a data controller will depend on the specific context in which we collect it. However, as a data controller, we will collect personal information from you where:

We have your consent to do so Where we need the personal information to perform a contract with you (e.g., to deliver the Services you have requested), or Where the processing is in our legitimate interests (and not overridden by your data protection interests or fundamental rights and freedoms).

In some cases, we may also have a legal obligation to collect personal information from you, or may otherwise need the personal information to protect your vital interests or those of another person.

Where we rely on your consent to process Account Data, you have the right to withdraw or decline your consent at any time. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.

If we ask you to provide Account Data to comply with a legal requirement we will make this clear at the relevant time and advise you whether the provision of your personal information is mandatory or not (as well as of the possible consequences if you do not provide your personal information). Similarly, if we collect and use your personal information in reliance on our legitimate interest which are not already described in this notice, we will make clear to you at the relevant time what those legitimate interests are.

Account Data – Access, control and correction of personal information and certain other important rights

As a user, you may update or correct most of your Account Data by logging in to your account to edit your profile or organization record. To make a request to have Account Data returned to you, removed, or to make additional corrections, please email our privacy team. Requests to access, correct, or remove your information will be handled within thirty (30) days and may be subject to a fee as permitted by applicable law.

Depending on where you reside, you may have the right to exercise additional rights available to you under applicable laws with regards to the personal information Tradescal LLC holds about you as a data controller, including:

Right of erasure: In certain circumstances, you may have a broader right to erasure of personal information that we hold about you – for example, if it is no longer necessary in relation to the purposes for which it was originally collected. Please note, however, that we may need to retain certain information for as long as you maintain an account for our Services, or as needed to provide you with our Services, for record-keeping purposes, to comply with our legal obligations, resolve disputes and enforce the Terms.

Right to object to processing: You may have the right to request that we stop processing your personal information and/or to stop sending you marketing communications.

Right to restrict processing: You may have the right to request that we restrict processing of your personal information in certain circumstances (for example, where you believe that the personal information we hold about you is inaccurate or unlawfully held).

Right to data portability: In certain circumstances, you may have the right to be provided with your personal information in a structured, machine-readable, and commonly used format and to request that we transfer the personal information to another data controller without hindrance.

If you would like to exercise such rights, please contact us. We will consider your request in accordance with applicable laws. To protect your privacy and security, we may take steps to verify your identity before complying with the request.

You also have the right to complain to a data protection authority about our collection and use of your personal information. For more information, please contact your local data protection authority.

USAGE AND WEBSITE ACTIVITY INFORMATION

When you visit our websites, we or our third-party service providers collect information about your use of the website: Your Internet service provider’s address, your location as determined by your Internet Protocol (IP) address, the name of the Website or advertisement directing you, your user agent, as well as your clicks and activity on our Websites. We use this information to understand how to make our Websites more available and user-friendly to our customers as well as to provide you with advertising that may be of interest to you.

GOOGLE AND ADOBE ANALYTICS

We use tools called “Google Analytics” and “Adobe Analytics” to collect some information we listed above about your use of the services. We use the information we get from Google Analytics and Adobe Analytics to improve the services. In order to collect this information, Google Analytics and Adobe Analytics may set cookies on your browser or mobile device,

or read cookies that are already there. Google Analytics and Adobe Analytics may also receive information about you from apps you have downloaded, that partner with Google or Adobe, respectively. We do not combine the information collected through the use of Google Analytics or and Adobe Analytics with personally identifiable information.

SOCIAL MEDIA

We engage with customers on various social media platforms like Facebook, Twitter, Pinterest, and Instagram. If you contact us on one of these platforms for customer service or otherwise, we may contact you via direct message. Those communications are governed by this policy as well as the policy of the relevant social media platform.

COOKIES AND OTHER TRACKING TECHNOLOGIES

“Cookies” are small amounts of data that are stored on your computer. They find their way to your browser via a Web server. Cookies flag information about your activity on our Websites. This information helps us improve our Websites and make them friendlier and easier to use and allows us to market to you more effectively. We never use cookies to save passwords, credit card numbers, or other highly confidential information. However, we use them and other tracking technologies to provide enhanced online marketing based on your interests and preferences.

GOOGLE ANALYTICS AND ADOBE ANALYTICS

The Google Analytics and Adobe Analytics products we use collect only anonymized IP addresses for IP’s located in the EU.

CANADA ANTI-SPAM LAW

We comply with the Canada Anti-Spam Law. Consumers who provide us a Canadian mailing address will not receive unauthorized Commercial Electronic Messages (as defined under the Canada Anti-Spam Law) unless these individuals have “opted-in” to receive Commercial Electronic Messages.

LEGAL REASONS WE COLLECT AND DISCLOSE CERTAIN INFORMATION

If you are a visitor from the European Economic Area, our legal basis for collecting and using the personal information described above will depend on the personal information concerned and the specific context in which we collect it. However, we will normally collect personal information from you only where we need the personal information to perform a contract with you (e.g. to provide you with our Services), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms, or where we have your consent. In some cases, we may also have a legal obligation to collect personal information from you.