1. INFORMATION WE COLLECT AND HOW WE COLLECT IT.
Information You Provide
We collect information you provide when you use our Services or otherwise engage or communicate with us as described below.
Identity Data, such as your name, date of birth, marital status, social security number, biometric identifiers, and other data on government-issued identification documents;
Contact Data, such as your email address, mailing address, and telephone number;
Financial Data, such as your bank account and payment card details, and information about your income, account balances, financial transaction history, credit history, tax information, and credit scores;
Profile Data, such as your username and password, your knowledge assessment results, your interests, preferences, feedback, and survey responses;
Stored Content, such as photos from your mobile phone gallery or contacts stored in your mobile device or email accounts. We only collect this information with your permission; and
Additional Data You Provide, such as via focus groups, survey responses, contests/sweepstakes, customer support, or other means.
Information We Collect Automatically
As is true of many digital platforms, we also collect certain information about you automatically when you use our Services, as described below.
Usage Information. We collect information about your activity on our Services, which includes device identifiers (like IP address or mobile device identifiers), pages or features you use, time and date of access, and other similar usage information.
Transactional Information. When you receive, submit, or complete a transaction via the Services, we collect information about the transaction, such as transaction amount, type and nature of the transaction, and time and date of the transaction.
Information Collected Through Tracking Technologies. We and our service providers also use technologies, including cookies and web beacons, to automatically collect certain types of usage and device information when you use our Services or interact with our emails. The information collected through these technologies includes your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique device or account ID, usage information and other similar information. For information about how to disable cookies, please see the Your Controls section below.
Information We Collect from Other Sources
We also obtain information about you from other sources as described below.
Vendors and Business Partners. We collect information about you from companies that we do business with, such as name, contact data, inferences about your preferences and attributes, as well as inferred fraud risk, from identity verification and fraud prevention partners.
Financial Account Linking. RoboTrader offers account linking and aggregation services.
Connected Services. If you link, connect, or log in to your RoboTrader Account with a third-party service (e.g., Google, Apple), the third-party service may send us information such as your profile information from that service. This information varies and is controlled by that service or as authorized by you via your privacy settings at that service.
Publicly Available Data. includes contact information, your interactions with our social media platforms, and other information from publicly available sources, such as public websites.
Advertising Data. We collect information in connection with our ad campaigns that surfaced on other platforms, such as the ads you clicked on and other interactions with our ads.
Data from other users. If you are in another user’s contact list and they choose to share that list with us, then we will collect the contact information and your association with that user.
2. HOW WE USE YOUR INFORMATION.
We use the information we collect for purposes described below or as otherwise described to you at the point of collection:
Maintain and provide the Services, including to process account applications, authenticate your identity, repair our Services, support, and handle billing and account management;
Send you transactional or relationship information, including confirmations, invoices, technical notices, customer support responses, software updates, security alerts, support and administrative messages, and information about your transactions;
Communicate with you about offers and other things we think you will be interested in, such as newsletters, product announcements, partner offerings, surveys, contests or sweepstakes, events or announcements;
Personalize our Services, such as by suggesting content or customizing content or ads we show you;
Monitor and improve our Services, including analyzing usage, research and development;
Facilitate contests, sweepstakes, and promotions and process and deliver entries and rewards;
Help protect the safety and security of our Services, business, and users, such as to investigate and help prevent fraud or other unlawful activity;
Protect or exercise our legal rights or defend against legal claims, including to enforce and carry out contracts and agreements; and
Comply with applicable laws and legal obligations, such as compliance obligations associated with being a regulated broker-dealer.
3. DISCLOSURES OF INFORMATION.
We are committed to maintaining your trust, and we want you to understand when and with whom we share information about you. We share information about you in the instances described below.
Authorized third-party vendors and service providers. We share information about you with third-party vendors and service providers who perform services for us, such as identification verification, fraud prevention, advertising, mailing services, tax and accounting services, contest fulfillment, web hosting, and analytics services. We use an identification verification service provider to determine whether a selfie you take matches the photo in your government-issued identification. With your consent, we may record your voice and send this data to our third-party partner to authenticate you and to help prevent fraud. The information collected from your photo and your voice by our third-party vendors may include biometric data.
Companies in which you hold securities. RoboTrader may provide your name, address, email address, and securities positions to requesting companies in which you hold securities.
Substantial corporate transactions. We may share information about you in connection with a substantial corporate transaction, a merger, consolidation, reorganization, financing, change in control or acquisition of all or a portion of our business by a third party, or in the unlikely event of a bankruptcy or similar proceeding.
Legal purposes. We disclose information about you if we believe that disclosure is in accordance with, or required by, any applicable law or legal process or to protect and defend the rights, interests, safety, and security of RoboTrader, our users, or the public.
With your consent. We share information about you for any other purposes disclosed to you with your consent.
We share information with others in an aggregated or otherwise de-identified form that does not reasonably identify you.
4. THIRD-PARTY TRACKING AND ONLINE ADVERTISING.
We use third-party advertising and analytics services to better understand your online activity and serve you targeted advertisements. For example, we use Google Analytics and you can review the “How Google uses information from sites or apps that use our services” linked here: http://www.google.com/policies/privacy/partners/ for information about how Google processes the information it collects. These companies collect information about your use of our Services and other websites and online services over time through cookies, device identifiers, or other tracking technologies. The information collected includes your IP address, web browser, mobile network information, pages viewed, time spent, links clicked, and conversion information. We and our third-party partners use this information to, among other things, analyze and track data, determine the popularity of content, and deliver advertisements targeted to your interests on our Services and other platforms, as well as to provide advertising-related services to us such as reporting, attribution, analytics, and market research.
For more information about interest-based ads, including to learn about options for opting out of having your web browsing information used for targeted advertising purposes, please visit www.aboutads.info/choices. You should also review your mobile device settings and controls for features that allow you to opt out or opt in to having certain information collected for behavioral advertising purposes. Please note, as a self-directed broker-dealer, we do not advertise on behalf of specific securities or investment options on our Services.
5. DO NOT TRACK.
Some web browsers transmit “do-not-track” signals to websites. We currently don’t take action in response to these signals.
6. YOUR CONTROLS.
Account profile. You may update certain account profile information by logging into your account.
Access to your device data. You may disconnect our mobile app’s access to certain stored device information through your device’s settings. For instance, you can withdraw permission for the app to access your contact list or photo gallery.
How to control your communications preferences. You can stop receiving promotional emails from us by clicking the “unsubscribe” link in those emails. We may still send you service-related or other non-promotional communications, such as account notifications, receipts, security notices and other transactional or relationship messages.
Affiliate sharing opt out. In some cases, you can limit sharing between RoboTrader. If you want to exercise this right, please contact us at email@example.com.
Disabling certain data sharing. You can limit how we share your data with our marketing partners to more effectively market our Services to you across sites and apps. When disabled, we will no longer share personal information with these partners for these purposes.
Cookie controls. Many web browsers are set to accept cookies and similar tracking technologies by default. If you prefer, you can set your browser to delete or reject these technologies. If you choose to delete or reject these technologies, this could affect certain features of our Services. Furthermore, if you use a different device, change browsers, or delete the opt-out cookies that contain your preferences, you may need to perform the opt-out task again.
7. NOTICE TO CALIFORNIA RESIDENTS.
This section provides additional details about the personal information we collect about California residents and the rights afforded to them under the California Consumer Privacy Act (“CCPA”). Please note that the CCPA does not apply to what is referred to as nonpublic personal information collected by financial institutions (like RoboTrader), as that information is subject instead to other financial privacy laws. As a result, the CCPA does not apply to most of the information that RoboTrader collects.
Subject to certain limitations and exceptions, the CCPA provides California residents the right to request more details about the categories and specific elements of personal information we collect, to delete their personal information, to opt out of any “sales” that may be occurring, and to not be discriminated against for exercising these rights. We do not sell information about you to third parties. In order to help RoboTrader deliver advertising and marketing on other platforms, we do allow third parties to collect information through our Services. Please see the “Third-Party Tracking and Online Advertising” section above for more details, including choices available to you.
In the last 12 months, we collected the following categories of personal information: identifiers (such as name, email address and IP address), Internet or other electronic network activity information (such as engagement with promotional messages and ads), and inferences (such as gender, based on your first name) derived from other personal information. For more details about the information we collect and the categories of sources of this information, please see the “Information We Collect and How We Collect It” section above. We share this information with the categories of third parties described in the “Disclosures of Information” section above.
California residents may make a consumer rights request to access or delete certain personal information not otherwise exempt from such requests under applicable law. A request may be made by logging into your RoboTrader account, navigating to the Security and Privacy menu, and selecting the option to either Download Personal Data or Request Data Deletion. You may also request assistance by sending an email to firstname.lastname@example.org. We may verify the request by asking you to provide information that matches information we have on file about you. You can also designate an authorized agent to exercise these rights on your behalf, but we will require proof that the person is authorized to act on your behalf and may also still ask you to verify your identity with us directly.
We do not knowingly collect or solicit any information from anyone under the age of 13 on these Services. In the event we learn that we have inadvertently collected personal information from a child under age 13, we will take reasonable steps to delete that information. If you believe that we might have any information from a child under 13, please contact us at email@example.com.
9. TRANSFER OF INFORMATION.
Our Services are currently designed for use only in the United States. If you are using our Services from another jurisdiction, your information may be processed in the United States or other countries that may not provide levels of data protection that are equivalent to those of your home jurisdiction.
10. CHANGES TO THIS POLICY.
11. HOW TO CONTACT US.