(Last Revised October 23, 2024)
Stock-Trak Inc. (“Stock-Trak”) recognizes and respects the privacy expectations of participants in its simulations. This Privacy Policy explains how we collect, use and protect your personally identifiable information and under what circumstances it may be disclosed. To see the information we collect and how it is used for users under 13 years of age, see our separate COPPA policy.
For the purpose of this Privacy Policy, “Personal information” shall mean information about you, which identifies you, such as your first name, your last name and email address.
This Privacy Policy is incorporated into our Terms & Conditions. All capitalized terms not defined herein are defined in the Terms & Conditions. We reserve the right to change this Privacy Policy from time to time, consistent with applicable privacy laws and other laws. Unless prohibited by applicable law, if we make any changes to this Privacy Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance by highlighting the change on our websites via email or our on-site Unified Messaging Center. If you do not agree with any material changes to this Privacy Policy, you can opt-out by emailing us within 30 days of the effective date of the updated Privacy Policy, in which case your registration will be cancelled, and you will not be able to use or Websites. If you do not opt-out during the said 30 days, if applicable, or continue to access or use our websites after the modifications have become effective, you will be deemed to be bound by the updated Privacy Policy.
1. Your Consent
By providing Stock-Trak with your Personal Information, you consent to the collection, use, disclosure and retention of that information by Stock-Trak in accordance with this Privacy Policy and as otherwise permitted by applicable law. You may withdraw your consent at any time, subject to legal or contractual restrictions and on reasonable notice to Stock-Trak, but then you might not be able to proceed with your intended interactions or transactions with Stock-Trak or otherwise receive the full benefit of Stock-Trak’s products and services.
2. The Information We Collect and How We Collect It
Stock-Trak collects a very limited amount of Personal Information from participants who register on its websites. In order to register, participants must first enter their date of birth. As a condition of registration, participants 18 years and over, provide us with their first name (optional), last name (optional) and email address (optional). With the exception of the PersonalFinanceLab.com website, other fields may be collected or used for demographic and marketing purposes or by third party processors for payment processing purposes, including your credit card information. For persons under the age of 18, the only Personal Information we collect at the time of registration is their first name and the first initial of their last name.
For our PersonalFinanceLab.com website, student participants are limited to entering only their first name, and first initial of their last name. Stock-Trak does not allow student participants to enter date of birth, email address, or full last names. If a school district implements a single sign-on solution (such as LMS integration) or rostering (such as ClassLink or Clever) to provision student accounts, the school has the option, at their sole discretion, to push additional Personal Information (such as full last name), for the purpose of populating teacher administration reports.
As an alternative registration method, certain of our websites, including without limitation HowTheMarketWorks.com and PersonalFinanceLab.com, will provide the option to have third-party administrators (including teachers), register the individuals in the participation group. Third-party administrators who select this registration option can specify the number of user accounts needed and then the system will auto-generate their user accounts (usernames with passwords) for the third-party administrator to distribute directly to the participation group. With this method of account creation the user registration process is bypassed and no Personal Information is collected from users.
3. Purpose of the Information
Stock-Trak collects Personal Information from our participants to facilitate the functionality of its sites and/or educational purposes. First and last name (or first name and first initial of last name in the case of persons under the age of 18) allows third-party administrators (specifically, contest administrators, i.e. teachers of a class contest) to keep track of an individual participant’s performance, activities and participation group ranking. Information such a participant’s email address, enables us to contact participants to announce contest updates, new contests or any other information that may be of interest to a participant such as contacting the winners. In the event that we need to contact a user who wins a contest and we do not have their email address, then we would attempt to contact the participant via the platform’s on-site Unified Messaging Center and / or via the third-party administrator. A participant’s email address is also used for certain transactional email messages on the website such as the registration confirmation email and change password requests.
4. To Whom We Disclose the Information
Stock-Trak is the sole owner of the information collected through our various websites. We do not sell or rent the Personal Information of our users. Data retention is for purposes of operating our websites and for the third-party administrator to monitor and evaluate the performance of the participants. We may share or disclose your Personal Information with certain third parties but only in ways that are disclosed in this Privacy Policy or with your express consent. For example, the third-party administrator will have access to the Personal Information of the participants in the groups that they have set-up. Third-party administrators also have access to view the activities and results (trading activity, virtual portfolio details, status of assignment tasks, etc.) of the users who participate in their participation group on the websites, where applicable. Names of participants may appear in the participation group rankings. Stock-Trak may publicize the names concerning winners of certain contests as we deem appropriate.
We may disclose your Personal Information to contractors or service providers, such as IT service management (Tierpoint, LLC), cloud based customer support services (Zoho Corporation) and email support (Twilio/SendGrid), who provide services or perform functions on our behalf (“Third-Party Processors”). These Third-Party Processors are permitted to use your Personal Information only for the purpose for which it has been provided and may not disclose it to any other third-party except at our express direction and consistently with this Privacy Policy.
5. Internet Based Advertising
With the exception of the www.stocktrak.com and www.personalfinancelab.com web properties, Stock-Trak may use interest-based advertising services provided by third-party vendors, (including but not limited to Google, Bing, LinkedIn, Facebook, InvestingChannel, and LiveRamp) to display advertisements on web pages visited by users of a Stock-Trak website. Advertising vendors may use unique identifiers, such as a user’s IP address, hashed email address, or information about a user’s browser or operating system to create an identification code that may be stored as a first-party cookie for use in online, in-app, and cross-channel advertising, and it may be shared with advertising companies to enable interest-based and targeted advertising. You can opt out of Google’s use of cookies by visiting Google’s Ads Settings. You can also opt out of a remarketing vendor’s use of cookies by visiting the Network Advertising Initiative’s consumer opt-out page at optout.networkadvertising.org .We also use Investing Channel as an ad provider. You can opt-out of Investing Channel’s cookies, pixels, and tokens here: stocktrak.com/do-not-sell-my-data, and opt-out of LiveRamp targeting based on hashed email addresses at https://liveramp.com/opt_out/.
There are no 3rd party advertisements, adverting vendor cookies, or 3rd party advertising tracking used on our www.stocktrak.com or www.personalfinancelab.com properties. For all other properties, tracking applies only to users who indicate that they are over the age of 16 at the time of registration.
6. Cookies
Stock-Trak may also collect additional information from participants and other visitors to the site through cookies. Cookies are small files that a site or its service provider transfers to your computer’s hard drive through your Web browser (if you allow) that enables the website’s or service provider’s systems to recognize your browser and capture and remember certain information. For instance, we may use cookies to help us understand your preferences based on previous or current site activity, which enables us to provide you with improved services. We may also use cookies to help us compile aggregate data about site traffic and site interaction so that we can offer better site experiences and tools in the future. You can find out more about how to manage cookies here: allaboutcookies.org/manage-cookies.
You may choose to decline or disable cookies if your web browser permits, but doing so will affect your ability to access or use certain features of Stock-Trak’s websites.
You can find out more about our Cookie Policy here.
7. Data Security and Retention
At Stock-Trak we take numerous steps to ensure that the Personal Information of our users is securely maintained. Firstly, we only collect a minimal amount of Personal Information during the registration process and we may provide an option for third-party administrators to generate user accounts without providing any Personal Information. All the user data and Personal Information that we collect is stored in a fully managed, professional, web-hosting environment, which is SSAE 18 Type 2 SOC 2 compliant. The data hosting service features a managed firewall, daily data backups (offsite), restricted physical access, data encryption in motion and at rest, redundancy and annual security audits. Personal Information and other data of inactive users gets purged from our database after 12 months of inactivity for participants and up to 60 months months for instructors / administrators (for example: teachers and professors).StockTrak is committed to meeting NIST data privacy and security standards as well as FERPA compliancy.
8. Opting Out of Changes To This Privacy Policy
From time to time, we may modify or update this Privacy Policy, which modification shall be effective immediately upon posting on the site, so please be sure to check back periodically. If we make any changes to this Privacy Policy that materially affect our practices with regard to the Personal Information we collect or have previously collected, we will endeavor to provide you with notice in advance via email or our on-site Unified Messaging Center. If you do not agree with any material changes to this Privacy Policy, you may opt out of those changes by e-mailing us within 30 days of the effective date of the updated Privacy Policy, in which case your registration will be cancelled, and you will not be able to use the website or participate in any ongoing or future contests. If you do not opt-out during the said 30 days, if applicable, or continue to access or use the website after the changes have become effective, you will be deemed to be bound by the updated Privacy Policy.
9. Corrections, Modifications and Deletions of Personal Information
To correct Personal Information you have submitted or request that it be deleted or if you have any questions about this Privacy Policy, please use the on-line form in the Contact Us section of the website or send an email to privacy@stocktrak.com.
Parents of users under 18 years of ages can contact us to review, modify or delete Personal Information of their children by using the on-line form in the Contact Us section of the website or by sending an email to privacy@stocktrak.com.
Additional Notice To Residents of the European Economic Area (“EEA”)
10. Data Controller
For purposes of the General Data Protection Regulation (the “GDPR”), we are the data controller for the purpose of data protection law, in respect of your Personal Information collected and used through your use of the websites, products and services. This is because we dictate the purpose for which your Personal Information is used and how we use your Personal Information.
11. Automated Decision Making
Stock-Trak will not use personal data for any monitoring or profiling activity or process, and will not adopt any automated decision making processes.
12. Your rights
Under the General Data Protection Regulation (GDPR), you have the following eight (8) rights:
13. Transferring Data Internationally
Stock-Trak transfers personal data we have both collected from you and stored, to the Third-Party Processors located in countries outside EEA. These Third-Party Processors also include third-party ad networks. Stock-Trak shall not transfer such personal data to a country or territory outside the EEA unless the transfer is made to a country or territory recognised by the European Union as having an adequate level of data security, or is made with the your consent, or is made to satisfy the legitimate interest of Stock-Trak in regard to its contractual arrangements with its clients. We will comply with Data Protection Act 1998 in respect of any such transfer.
By using this website, you consent to the transfer of your Personal Information to the Third-Party Processors located in countries outside the EEA.
14. Legal Bases for Processing Your Data
15. Data Breach
In the event of an unauthorized release, disclosure or acquisition of your Personal Information that compromises the security, confidentiality or integrity of your Personal Information maintained by Stock-Trak (“Data Breach”), Stock-Trak shall notify you within a reasonable time after the incident. Notices of Data Breach incidents will be sent using our on-site Unified Messaging Center. Stock-Trak will adhere to all applicable governmental requirements with respect to such Data related to your Personal Information.
The security breach notification shall include, to the extent known by Stock-Trak, a list of the types of Personal Information that were or are reasonably believed to have been the subject of the Data Breach, and if known at the time of the notice, the date or estimated date of the Data Breach and a general description of the Data Breach incident. Stock-Trak will have a written incident response plan that reflects best practices and is consistent with industry standard and governmental authorities for responding to a Data Breach as relates to Personal Information.
16. Resolving Complaints
If you have any concerns about the way Stock-Trak is handling your Personal Information, please let us know immediately. You may email us directly at privacy@stocktrak.com with the subject “Privacy Concerns”. We will do our best to respond as soon as possible. You may also contact us at:
Stock-Trak Inc.
Att: Andrew Zeidel
101 Marcel-Laurin Boulevard, #330
Montréal, QC H4N 2M3
Canada