PRIVACY POLICY

GrowAPairandTrade (hereafter referred to as “GAPAT”) is committed to treating personal information obtained through the websites owned or operated by GAPAT with respect for user privacy concerns and in accordance with this Privacy Policy.  “User” is defined as any person who for any reason accesses any website owned or operated by GAPAT.

This privacy policy is applicable to all business conducted by GAPAT (the company that created, operates, and owns GrowAPairandTrade.com).  All personally identifiable information collected by GAPAT when users visit the GrowAPairandTrade.com websites or information shared with GAPAT by GAPAT business partners is kept confidential and is used for internal purposes only.  Personally identifiable information is defined as information that can identify an individual, including but not limited to name, address, telephone number, etc.  Additional information collected by GAPAT for internal purposes may include user IP address and user website usage information. GAPAT does not disclose any personally identifiable information to persons or entities outside of GAPAT.

This privacy policy does not apply to personally identifiable information collected by any entity except GAPAT. Any information collected from any entity other than GAPAT including entities that may advertise or offer products or services on GrowAPairandTrade.com is subject to the privacy policies of the third-party entity.

Registered Members

In order to access specialized features of GAPAT websites, such as GAPAT asset picks, market analyses videos, and private mentoring, users must be registered GAPAT website members. When users register with GAPAT, personally identifiable information collected from users may include name, email address, city, state and zip code, and telephone number as well as other information, such as how users heard about GAPAT.  In addition, when users access certain specialized features offered to registered GAPAT website members, GAPAT may collect additional information about users, such as credit card information, portfolio information, financial information, employment information, and other personally identifiable information.  All additional information listed above is bound by the GAPAT privacy policy as described herein.

Promotions and Surveys

Contests, sweepstakes, other promotions or surveys that may be offered by GAPAT may require GAPAT to request additional personally identifiable information from participants related to the topic of the survey, entry in the promotion, prize notification or fulfillment.  Information collected in this capacity is bound by the GAPAT privacy policy as described herein.

Use of Information

GAPAT uses personally identifiable information collected from users for the following general purposes:

•  to fulfill user requests for specific products and services;
•  to customize the advertising and content;
•  to improve website design and content;
•  to contact users about special offers, products or services;
•  to enter users in promotions at their specific request
•  to provide users with customer service.

Information Sharing and Disclosure

GAPAT will not sell, share, or otherwise disclose any personally identifiable information about current or former GAPAT website users to third party companies or individuals, except as permitted or required by law.

GAPAT may share or disclose personally identifiable information about users to other companies or individuals when GAPAT:

•  has the consent of the user to share the information;
•  utilizes third party service providers to provide products, services or functions on the behalf of GAPAT (such as sending emails or processing credit cards), and requires these service providers to agree to maintain the confidentiality of  personally identifiable information of GAPAT users and not to use this personally identifiable information for any reason except to carry out the purpose(s) for which they were contracted by GAPAT;
•  needs to protect legal rights (for example, user fee collection or Terms of Use enforcement);
•  must comply with applicable laws, regulations, or legal or regulatory process; or
•  is in connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise) of all or a portion of the GAPAT business.

Aggregate information is information that GAPAT (or third-party service providers on our behalf) collect about GAPAT website users on an anonymous basis. GAPAT may share aggregate demographic and usage information with prospective and actual business partners, advertisers, and other third parties.

Cookies

GAPAT (or third-party service providers on the behalf of GAPAT) may set and access cookies on GAPAT-user’s computer(s). Cookies are used to understand website usage and improve the content and offerings on websites owned and operated by GAPAT. Cookies may be used to identify registered users, personalize user’s experience at GAPAT websites, save user password(s) in password-protected areas, and display relevant content, products, services, and advertising. To the extent that GAPAT utilizes third-party service providers to set and access cookies on the computer(s) of GAPAT website users on behalf of GAPAT, GAPAT requires such service providers to agree to maintain the confidentiality of the information collected and not to use such information for any reason except to carry out the purpose(s) for which they were contracted for their service(s).

GAPAT uses reputable third parties to present or serve some or all of the advertisements on websites owned and operated by GAPAT. These third-party network advertisers may set and access their own cookies on user’s computer. The use of cookies by third parties is subject to such third party’s own privacy policies.  Users are responsible and encouraged to adjust settings related to cookies on their computer(s) depending on their needs.  Users are reminded that if browsers are set to reject cookies, they may be prevented from taking advantage of certain features offered through GAPAT websites.

Security

Personally identifiable information collected by GAPAT is password-protected. This information is stored in limited access servers. GAPAT maintains (directly and through our agents) physical, electronic, and procedural security safeguards to protect the personally identifiable information collected by GAPAT.

Children

Due to the financial nature of the business conducted by GAPAT, websites owned or operated by GAPAT are not designed to appeal to children under the age of 18. GAPAT neither knowingly solicits any information from children nor knowingly markets the GAPAT website or its products or services to children. Users under the age of 18, are requested not to use or register on websites owned or operated by GAPAT.

Transfer to the U.S.

Information collected by users who are located outside of the United States will be transferred to the United States.  User registration on websites owned and operated by GAPAT is accepted as consent to this transfer.

Changes to Privacy Policy

GAPAT may change this policy from time to time without notice. Any changes to this policy will be promptly posted on websites owned and operated by GAPAT.  Use of websites owned or operated by GAPAT after any changes have been posted will constitute the user’s agreement to the modified Privacy Policy.