Privacy Policy

ProTrading Research, LLC

In compliance with the law, we update this policy at least once per year.  The last update to this policy was on July 12, 2024.

WE RESPECT YOUR PRIVACY AND WILL NOT COLLECT, SELL OR SHARE YOUR INFORMATION, EXCEPT AS AUTHORIZED BY YOU AND ALLOWED OR REQUIRED BY LAW. WE DO NOT MONITOR, COLLECT, STORE OR SHARE YOUR DATA EXCEPT AS SET FORTH BELOW.

This Privacy Policy supersedes all prior versions and sets forth the data privacy practices of Pro Trading Research, LLC (“ProTrading,” “we,” “us,” or “our”) and applies solely to visitors and users (“consumers” or “you”) of our website and other online applications owned and operated by us, as well as to certain individuals we interact with over the phone or via SMS, including our existing prospects and customers. This policy does not apply to any third-party websites we may link to and we assume no responsibility or liability regarding the same.

Our websites may at times record your interactions with it, including for example your interactions with our online consent/opt-in forms and webchat features.  Do not make any use of our sites if you do not consent for us to engage in this practice.

If you are an existing customer, your use of our websites and other services is also governed by the purchase terms which existed at the time of your purchase, along with any addendums and written modifications thereto.

We adopt this policy to comply with state data privacy statutes in CA, CO, CT, DE, IN, IO, KY, MD, MN, MT, NE, NH, NJ, OR, RI, TN, TX, UT and VA, most of which are very new and some of which have not quite taken effect. Nothing herein may be construed as creating any obligations for us beyond what is required by the law.

Disabled users who need these disclosures presented in an alternate medium, may contact us at the email address or telephone number listed further below.

Your Rights as a Consumer

Depending upon where you live and as more fully explained below, you may have significant rights related to the privacy of your personal information, including:

• Right to access your data.
• Right to correct your data.
• Right to have your data deleted.
• Right to opt-out of certain forms of processing of your data.
• Right to portability of your data.
• Right to opt-out from the sale of your data.
• Right to opt-in for certain sensitive data processing.
• Right against certain forms of automated decision-making about your data.
• And, in California, the right to bring a private action to protect your data.

Information We Collect

We collect your personal information on our website in order to contact you with the information you request.  We also collect your information in order to allow us and our conspicuously listed/disclosed partners to contact you with the marketing offers you have requested or which we believe you may be interested in based upon the information you submit.

As more fully set forth below, and by way of example only, we affirmatively collect various categories of information about you, including your first and last name, address, telephone number, email address, date of birth, social security number, income, pay frequency, rent, housing type, names of creditors, outstanding balances on debt, status of the payment of debt, personal expenses, amount of debt, employment information, credit score, data from credit reports, bank account information, military status, marital status, data collected through recorded calls, cookies, pixels, session replay, IP address and other geolocation data, and other personal information.

As explained at the point of online telephone number collection, when you type your name and telephone number into our website or otherwise submit the same to us, you agree that this shall act as your electronic signature and express written consent that ProTrading, along with its agents, assigns and listed partners, may call and text you at the number(s) provided (or provided later), with marketing offers and other information, including possibly using an automatic telephone dialing system, prerecorded messages, and artificial/AI voices, even outside of normal calling windows. Consent is not a condition of purchase and you may opt-out later. Standard rates apply and all calls may be recorded and monitored. By consenting, you are specifically requesting that we share your information in this manner and for these purposes. You agree to do business with us electronically and to receive copies of these terms electronically. You can withdraw your electronic signature or request a paper copy by emailing us at [email protected].

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”). Specifically, we have collected the following categories of personal information within the last twelve (12) months:

We obtain the categories of personal information listed above from the following categories of sources:

• Directly and indirectly from activity on our websites.
• Directly from website visitors who submit information on web-opt-in forms and third-party lead vendor forms
• Directly from credit reporting agencies and data aggregators, some of which is aggregate data and some individual.
• Directly from third-party marketers and their agents, who might collect permission from you to share your information with us.
• From third-parties that interact with us in connection with the services we perform. Including, for example, from advertising networks, consumer data resellers, data analytics providers, internet service providers, social networks and operating systems and platforms. We also collect information from government entities and from publicly available records and databases.
• Directly from you over the phone, if you call us or we call you.

Use of Personal Information

We may use or disclose the personal information we collect for one or more of the following business purposes:

• To provide you with the SMS alerts you request from us.
• To fulfil our obligations to existing customers.
• To document our compliance with the law.
• To provide it to the party or parties listed in the website form on which you provided your information, per your request.
• To fulfill or meet the reason you provided the information.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To provide you with information, products or services that you request from us.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections.
• To improve our website and present its contents to you.
• For testing, research, analysis and product development.
• As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your personal information or as otherwise set forth in the various state data privacy statutes and regulations.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party (eg: marketing partners, service providers and data aggregators) for a business purpose. When we disclose your information for business purposes our contracts state the purpose and requires all parties use personal information for the sole purpose of fulfilling the contract and also that all personal information be kept confidential.

In the preceding twelve (12) months, we have disclosed the following categories of personal information for a business purpose: unique personal identifiers (including your SSN if you live in TX), commercial information, internet or other electronic network activity information, geolocation information (including your IP address if captured by our website), sensory data (including call recordings), and inferences or conclusions drawn from personal information.

We may on occasion disclose your personal information for a business purpose to the following categories of third parties:

• Purchasers or users of our collected data.
• Marketing partners.
• Our corporate and contractual affiliates.
• Service providers.
• Third parties to whom you or your agents authorize us to disclose your personal information in connection with products or services provided to you.

In the last twelve (12) months, we have sold the categories below of personal information for a business purpose:  (Note personal information is generally not considered “sold” if it is shared at the specific request of the consumer.)  unique personal identifiers (including your SSN if you live in TX), commercial information, internet or other electronic network activity information, geolocation information (including your IP address if captured by our website), sensory data (including call recordings), and inferences or conclusions drawn from personal information.

Basic Categories of Rights

As set forth herein, if you live in you may have most or all of the following rights related to the privacy of your personal information, including:

• Right to access your data.
• Right to correct your data.
• Right to have your data deleted.
• Right to opt-out of certain forms of processing of your data.
• Right to portability of your data.
• Right to opt out from the sale of your data.
• Right to opt-in for certain sensitive data processing.
• Right against certain forms of automated decision-making about your data.
• And, only in California currently, a right to bring a private action to protect your data.

Access to Specific Information and Data Portability Rights

Residents of the above data privacy states, have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (if we can), we will disclose to you:

• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:  sales, identifying the personal information categories that each category of recipient purchased; and disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

In certain cases, we might not be able to successfully verify your identity, or the information may be too sensitive to disclose.  In such cases, we will notify you why we were not able to provide the information to you.

Deletion Request Rights

After we have verified your identity and that you reside in one of the current, active data privacy states, you have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service providers to:

• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the law.
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by calling us at +1 (800) 467-0445, or by emailing the request to: [email protected].

Please note that only you or a person properly registered that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.  Making a verifiable consumer request does not require you to create an account with us.  We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

If we can accurately verify your identity based upon the information in your request, we will not require additional ID before processing your data demand.  If we need to further verify your identity, you may need to either provide a legible copy of your government-issued photo ID, or provide at a minimum at least 3 specific data points which we already maintain about you. We will try not to collect more personal information than is necessary to successfully verify your identity.

Response Time and Format

We will generally confirm receipt of your Request within 10 days and fulfil your request within 45 days, or up to 90 days if we notify you as to why we need more time.

We will deliver our written response by mail or electronically.  Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt.  The response we provide will also explain the reasons we cannot comply with a request, if applicable.  For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded.  If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Personal Information Sales Opt-Out and Opt-In Rights

If you are 16 years of age or older, you have the right to direct us to not sell your personal information at any time (the “right to opt-out”). We do not sell the personal information of consumers we actually know are less than 18 years of age, unless we receive affirmative authorization (the “right to opt-in”) from either the consumer who is between 13 and 18 years of age, or the parent or guardian of a consumer less than 13 years of age. Consumers who opt-in to personal information sales may opt-out of future sales at any time. To exercise the right to opt-out, you (or your authorized representative) may submit a request to us by visiting the following our webpage and sending us a message.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sales at any time by visiting our website and sending us a message. We will only use personal information provided in an opt-out request to review and comply with the request.

Minors

Minors may not use our websites or submit information to us.  We do not intentionally collect information about minors.

Non-Discrimination

We will not discriminate against you for exercising any of your privacy rights. Unless permitted by the law, we will not:

• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

New Jersey Public Servicemembers

We value the privacy of public service members and do not publish or otherwise make available the information related to the same to the public.  If you are a public servicemember in New Jersey, including for example a current or retired New Jersey judge, prosecutor or police officer, do not submit any private, non-public contact information to us.  If you do, you agree that, to the extent your non-public contact information is protected by New Jersey’s “Daniels law,” you will exercise your right to opt-out (a non-disclosure request) only by emailing your request to [email protected], and you will allow us a reasonable period to recognize and honor your request.

Changes to this Privacy Policy

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date. Your continued use of our website following the posting of changes constitutes your acceptance of such changes.

Other California Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) provides California residents with the right to request information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make a request, please contact us at the following email address or phone number: +1 (800) 467-0445, or by filling out the request in the below email link: [email protected].

Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your personal information, your choices and rights regarding such use, or wish to exercise your rights under applicable privacy laws, please do not hesitate to contact us at:

Attn: Privacy Officer
ProTrading Research, LLC
203 N La Salle Street, Suite 2100
Chicago IL 60601
Telephone:  +1 (800) 467-0445
[email protected]