Privacy Policy Corp
Effective October 15, 2019

Welcome to! We work hard to protect your personal information and ensure your information is kept private and secure. The following privacy policy outlines the types of personal information that Corp, including through’s websites/platforms, and our mobile applications for iOS and Android devices. It also explains why we collect yourinformation and how we use it.
Privacy is important to We will never rent or sell your information to anyone.If you have any questions or if you believe that has not adhered to this privacy policy, please send us a note at

Information Collection collects Personal Information about our customers from the following two main channels: Website Account and General Communications

In order to provide high quality educational materials and services to you, when you visit our website, request materials from us, register for events, or contract with us, we will collect data from you. We will receive your information in these circumstances, as examples:

  • Visiting and using our website;
  • Account Application Forms and other documents and data submitted by customers, such as customer name, residential address, age, time zone, date of birth, investment experience, amount available for investing, annual income, and estimated net worth;
  • In case of Customer Subscription Transactions with such as ordering our products/services, we may require that customers to provide credit card or bank account information, and government issued ID numbers (such as social security numbers);
  • Communications with including with customer service representatives and our LiveChat function. We refer collectively to these interactions as “Website Services”. We explain below how we collect and use your information collected through the Website Services.

Website Account and General Communications
What We Collect
We (or third-parties acting on our behalf) may collect your information, including your Personal Information, when providing the Website Services including:

  • Name
  • Email
  • Address
  • Phone Number
  • Country of Residence
  • Date of Birth/Age
  • Time zone
  • Amount to invest
  • IP address.
  • Government Identifiers: Social Security Number/Passport Number & Passport Expiry (which we electronically verify).
  • Bank / Credit Card Data (just in case of subscription)

Our service is not directed towards anyone under the age of 18. If a parent or guardian becomes aware that his or her child under the age of 18 has created an account with and/or provided us with personally identifiable information, please contact us at Additionally, if we become aware at any point that a child under the age of 18 is using our service, we will terminate his orher account.

How Uses Personal Information
We may hold and retain information about you for various purposes based on different reasons.
Some of the information we collect from you we need to enable us to deliver the Website Services to you in accordance with our terms, sometimes we are required by law and regulations to collect and process this information about you. At other times, we consider it is in our legitimate business interests to collect and process this information, taking into consideration your privacy rights. We may use your information to:

  • Fulfill your orders or respond to requests you make in connection with providing the services under our terms with you
    To provide you with a response pursuant to your request and your agreement with the applicable terms, we will collect and use Personal Information including your name and email address.
  • Provide our Website Services to you, including support through our LiveChat function.
    In order to perform the Website Services under the contract between you and, we have to collect certain Information from you such as your name and contact details. Without this information, we may not be able to deliver the services which you request from us.
  • Improve and develop the Website Services
    We look for ways to innovate and advance our Website Services. We will use Information about how you use the Website Services, including how you interact with various aspects of the Website Services, the duration for which you use the Website Services and content that is of interest to you, in order to do this. It is in our legitimate business interests to use Personal Information in this way to develop improved Website Services.
  • Send administrative information, changes to contract terms or policies
    Where we make updates to terms and policies we are required under certain laws and under our contract with you, to notify you of these changes. Other administrative communications, may be necessary in order for us to perform our obligations under the contract with you, or may be sent out in line with our legitimate business interests.
  • Send marketing communications like product announcements, educational materials or upcoming online or offline events, where you have not objected to receiving these or with your consent where required. This may also include inviting you to participate in various promotional activities
    It is in our legitimate business interests to generate growth for our own business to ensure we continue to generate development for our company and drive sales of our products and services. We will carry out marketing campaigns in accordance with other applicable laws.
  • Research and analyze how our Website Services are used via cookies, web beacons and other similar technologies to personalize the Website Services. (For more information about our use of cookies and your choices to opt-out of their use, see “Cookies” at section below.)

We use your information in our legitimate business to understand how you interact with our Website Services and to deliver relevant content to you online. Therefore, another objective is to diagnose and fix technical issues and monitor the security of our environments

We need to understand how our Website Services are performing in order to prevent and address any issues that may present themselves with regard to technical and security operations. We may process your Personal Information for this purpose in our legitimate business interests to protect the integrity of the Website Services

  • To comply with any applicable law, regulation, legal process, or governmental request.
  • For any other purpose disclosed to you in connection with our Website Services from time to time

If we intend to process your Personal Information for a purpose other than that set out above, we will provide you with information prior to such processing.

It is also in our legitimate business interests to process your Personal Information to protect our rights or property, or the security or integrity of our Website Services.

Third-Party Content. The Website Services may offer access to third party services. These services may collect and use your information. This Privacy Policy does not extend to third-party apps or add-ons (which may also collect your Information) even if packaged by or offered through the Website Services.

When signing up as a subscriber we collect oersonal Information including payment details, as set out above, in order to provide access to the Dashboard/Platform under the contract between and you. We are also required to keep these payment details to comply with our own legal obligations.

We also collect and process usage data when you use our Platform (e.g. IP address, session duration, activities undertaken on the Platform and other use data) (“Usage Data”) in order to provide, maintain, and improve our Platform.

In addition, we collect and process data about our Educational newsletter Dashboard/Platform, features or users in order to improve the Platform (“Analytics Data”). Analytics Data may include information about the devices operating the Platform (e.g. browser type/version, OS type/version, device type/version), or such other similar information about user configuration or operation of service features or functionality.

Whilst both Usage Data and Analytics Data may not contain information that we can use to identify you in the "real world" (such as a name or address), we collect this data and store it against a uniquely assigned ID.

We use algorithms to issue our signal lists.
Usage Data. Specifically, may use Usage Data to:

  • Positively identify and determine eligibility of customers opening accounts;
  • Complete the paid subscription;
  • Effect, administer or enforce transactions requested or authorized by the customer and
  • Maintain or service the customer’s account with

Our lawful basis for using Usage Data is in order to take steps to enter into a contract with you or as is necessary for the performance of a contract already in place between us. Analytics Data. uses Analytics Data to help us better understand how our Platform is being used, make improvements, and develop new features, products and services. We may use this data to:

  • Better understand how our users configure and use our Platform;
  • Determine which configurations or practices optimize performance (e.g. best practices);
  • Perform data analysis and audits;
  • Identify, understand and anticipate performance issues and the environmental factors that affect them;
  • Other such business purposes relating to the operation, improvement, or development of our Platform.

The use of this Analytics Data, for the purposes described in the above, is carried out pursuant to our legitimate business interests, to develop, expand and improve our Platform offering. We are sure to balance our legitimate business interests with your privacy rights and we take steps in how we process and use Usage Data and Analytics Data to protect these.

Personal Information collected online may be combined with other information customers provide to in hard copy or through the help desk.

Disclosure of Customer Personal Information may disclose Personal Information of current and former customers to affiliated and non-affiliated third party entities in connection with our business, including, without limitation:

  • to’s service providers that perform services on’s behalf under written agreements which restrict use of Personal Information to the limited purposes for which it is provided to them and to refrain from further use or disclosure except as permitted by law. This may include companies who perform background checks or identity verification, infrastructure, data analysis, business intelligence, customer relationship platform providers, marketing support services providers, cloud service providers, and IT service providers.
  • to communicate with credit reference and information agencies.
  • to strategic partners to permit them to assess your interest in Website Services, including foreign exchange payments and international money transfers.
  • to affiliates, who are permitted to disclose and use the information only to the extent that may disclose and use the information under this Privacy Policy
  • in the ordinary course of business to’s attorneys, accountants and auditors
  • to persons holding a legal or beneficial interest relating to the customer’s account
  • to persons acting in a fiduciary, representative, or attorney capacity in relation to an account
  • to protect against actual or potential fraud, unauthorized transactions, claims or other liability
  • to government, regulatory or law enforcement agencies to the extent permitted or required by law, or to comply with applicable legal requirements
  • to monitor our services, whether provided by ourselves or a third party
  • to comply with civil, criminal or regulatory investigations, or judicial process, summons or warrant by appropriate federal, state, or local authorities or
  • in the event of a proposed or actual reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of’s business, assets or stock (including in connection with any bankruptcy or similar proceedings).

The client confidentiality obligations set out in our Privacy Policy do not and will not apply to, and in respect of, any confidential information required to be disclosed (by us or you) pursuant to any applicable law, or the lawful request of any court of competent jurisdiction, government agency, or regulatory body, provided in each case you (or we) notify and consult with us (or you) in advance and as to the timing and content of such disclosure, except where applicable law prohibits us (or you) from doing so.

Except as stated in this Privacy Policy, will not share Personal Information about any present or former customer with any non-affiliated third party without the customer’s prior written consent.

How we secure your Personal Information

All information you provide to us is stored on our secure servers. has implemented procedures to safeguard customer Personal Information. restricts access to Personal Information to those employees who need to know that information in order to provide our products or services to them. maintains physical, electronic and procedural safeguards to safeguard Personal Information. protects customer account information by keeping it on the secure portion of its website, using firewalls and other security technology to protect its network and systems from external attacks, and by requiring customers to enter a unique user ID and password to access our systems. conducts periodic internal audits of its business practices and procedures, examining its confidentiality standards and information access, in order to best protect our customers’ Personal Information.

Where we have given you (or where you have chosen) a password which enables you to access certain parts of our Website Services and Platform, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we will do our best to protect your Personal Information, we cannot guarantee the security of your data transmitted to our Website Services and Platform; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.

How long we retain your Personal Information for

We retain Personal Information(a) in relation to the Platform, for as long as you have an account with us in order to meet our contractual obligations to you and for seven years after that to identify any issues and resolve any legal proceedings, and (b) in relation to Website Services, for 12 months unless such data is likely to relate to a contract you may/have entered into in the future, and subject to any subject access requests you may make. We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.

Customer Recourse

Any concerns a customer may have regarding’s Privacy Policy or specific complaints about how customer Personal Information has been collected, used or disclosed should be forwarded in writing to’s Privacy Officer. will thoroughly investigate the complaint and will take whatever actions are warranted and notify the customer once this has been done.


Cookies are small text files placed in visitors’ computer browsers to store their preferences. The Website Services, our Platform, and our third party partners, collect and store information that is generated automatically as you use it, including your preferences and anonymous usage statistics. collects information about your device and uses tracking mechanisms such as cookies to: (i) facilitate customer use of our website and mobile applications, (ii) enable customization of our online services and website features, (iii) avoid customer re-entry of data, (iv) store customer preferences for certain kinds of information, (v) enhance security measures, and (vi) gather data about usage of our website and mobile applications for research and promotions. uses cookies from third party service providers to facilitate website tracking and security measures and may share the information collected with third parties acting as our service providers, who are required to maintain the confidentiality of the information.

We use these cookies and other technologies on the basis that they are necessary for the performance of a contract with you, or because using them is in our legitimate interests (where we have considered that these are not overridden by your rights), and, in some cases, where required by law, where you have consented to their use.

We use the following types of cookies:

  • Essential cookies. These are cookies that are required for the operation of our Website Services and/or our Platform and under our terms with you. They include, for example, cookies that enable you to log into secure areas of our Website Services and/or our Platform.
  • Analytical/performance cookies. They allow us to recognize and count the number of visitors and to see how visitors move around our Website Services and/or our Platform when they are using it. This helps us for our legitimate interests of improving the way our Website Services and/or our Platform works, for example, by ensuring that users are finding what they are looking for easily.
  • Behavioral cookies. These are used to recognize you when you return to our Website Services and/or our Platform. This enables us, subject to your choices and preferences, to personalize our content, greet you by name and remember your preferences (for example, your choice of language or region).
  • Marketing cookies. These enable you to experience more relevant online content and see adverts which are aligned with your interests, as indicated by your activity on our site.

Customers can configure their browser preferences not to accept these cookies however this may result in reduced functionality. Some third-party vendors that provide ads on web pages may use cookies to collect details on customer website visits and other data (but not names, addresses, email addresses, or telephone numbers) in order to provide ads about goods and services of particular interest to individual customers. For more information on this practice or to opt out, customers can visit the Network Advertising Initiative site. Opt-outs are also available for Google Analytics and TUNE Marketing.

Links to non- websites

The website may provide links to third-party websites for customer convenience and information. If customers decide to access those links, they will leave the website. does not control those third-party sites or their privacy practices, which may differ from does not endorse or make any representations about third-party websites. Any Personal Information customers choose to give to unrelated third parties is not covered by’s Privacy Policy. Customers should review the privacy policy of any third- party website before submitting Personal Information. Some third-party companies may choose to share their Personal Information with That sharing is governed by the disclosing company’s privacy policy.

Notification of Policy and Policy Changes provides an initial notice of its Privacy Policy to customers at the time it establishes a customer relationship, and at least annually thereafter, and the Privacy Policy is posted on its website / APP. Updates will be posted on the website, so our customers will always know what information we collect, how we use it, and what choices they have. This privacy policy was last updated on Oct 15, 2019.

Your Rights as a California Resident

Residents of California have the right to request from us certain information with respect to the types ofpersonal information we share with third parties for those third parties’ direct marketing purposes and the identities of the third parties with whom the business has shared such information during the immediately preceding calendar year. To exercise your rights, you may make one request each year by emailing us at Your request should specify your full name and the email address you used when submitting personal information to us.

Your Rights as a Vermont Resident

We do not share nonpublic personal financial information we collect about Vermont residents to non-affiliated third parties except for our everyday business purposes or as otherwise permitted by law. If you wish to revoke any authorization to share your nonpublic personal financial information, which you have provided to us by entering into our Customer Agreement, please contact us at Please note, however, that we will not be able to provide you with services through without the ability to share this financial information.

For Customers Who Are Resident in the European Union (EU)

The data that we process in relation to you may be transferred to, and stored at, a destination outside the European Economic Area (EEA) that may not be subject to equivalent data protection law. It may also be processed by staff situated outside the EEA who work for us or for one of our suppliers.

We may transfer your personal information outside the EEA:

  • In order to store it
  • In order to enable us to provide goods or services to and fulfill our contract with you or the company you work for. This includes order fulfillment, processing of payment details, and the provision of support services
  • Where we are legally required to do so
  • In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.

Where your information is transferred outside the EEA, we will take all steps reasonably necessary to ensure that your data is subject to appropriate safeguards, such as relying on a recognized legal adequacy mechanism, and that it is treated securely and in accordance with this Privacy Policy. We may transfer your personal information to the following countries outside the EEA:

  • Any member of our group, which means our subsidiaries, our ultimate holding company and its subsidiaries, the details of which are set out in the table below, and for these transfers we use European Commission approved contractual clauses for transfers (referred to as “Model Clauses”)

Group Member Location Corporation United States

Our vendors, details of which are set out below, and for these purposes we use Model Clauses:

Group Member Location
Email Service Provider United States
Cloud Data Storage United States
Messaging Service Provider United States
Chat Service for Customer Support United States, Brazil
Team Collaboration Software United States, Brazil
Customer Relationship Management United States, Brazil
Identity Verification United States
Business Intelligence United States
Marketing Support Services United States, Brazil
Funds Processing United States

Your Data Subject Rights

You have the right under certain circumstances:

  • to receive information about the processing of Personal Information concerning you. You are entitled to access your Personal Information
  • to request the rectification or erasure of your Personal Information held by us
  • to object to the further processing of your Personal Information, including the right to object to marketing
  • to request that your provided Personal Information be moved to a third party.

Depending on the context of your request, such as erasure, we may not be able to provide you with access to some or all of the Website Services and/or Platform, since we process your information in order to provide you with such access.

Your right to withdraw consent
Where the processing of your Personal Information by us is based on consent, you have the right to withdraw that consent at any time by contacting us as per section below.

How to exercise your rights
You can also exercise the rights listed above at any time by contacting us at

If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority (to your habitual residence, your place of work, or an alleged infringement of the General Data).
Protection Regulation (GDPR) (see The local data protection authority can provide further information about your rights and our obligations in relation to your Personal Information, as well as deal with any complaints that you have about our processing of your Personal Information.

Contact Us

We will never ask you for security information such as passwords over the phone or by email. If you receive a call or email which you are not sure has come from Corporation, please contact us
We value our customer's opinions. If they have comments or questions about our Privacy Policy, they are invited to us at or write to us at: Privacy Office, Corporation, 409 NW 10th Terrace, Hallandale Beach, FL – 33009.