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PRIVACY POLICY (Last Revised September 4, 2019)

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, any such change will apply thirty (30) days from the date of posting on our websites, unless you object (“opt-out”) as provided below before that date. Your continued use of this site following such changes signifies your acceptance of those changes.

  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. For persons under the age of 16, the only Personal Information we collect at the time of registration is their first name and the first initial of their last name. As a condition of registration, participants 16 years and over, provide us with their first name, last name and email address (which is optional). Other fields may be collected or used for demographic and marketing purposes or by 3rd party processors for payment processing purposes, including your credit card information.

As an alternative registration method, certain of our websites, including without limitation http://www.HowTheMarketWorks.comhttp://www.PersonalFinanceLab.com, and http://www.NationalSMS.com, will provide the option to have third-party administrators 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 our simulations. First and Last Name (or First Name and First Initial of Last Name) allows third-party administrators to keep track of an individual participant’s performance, activities and participation group ranking. The information further allows 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 contact the third-party administrator. 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 site. 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 3rd 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: https://www.tierpoint.com/), cloud-based customer support services (Zendesk, Inc.: https://www.zendesk.com/) and email support (Twilio/SendGrid: https://sendgrid.com/), 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

Stock-Trak may use interest-based advertising services provided by third-party vendors (such as Google, Bing, LinkedIn and Facebook) to display advertisements on third-party websites and social media sites visited by users of a Stock-Trak website. Advertising vendors (such as Google, Bing, LinkedIn and Facebook) use cookies, pixels or tokens – unique identifiers of a web browser on a specific computer that are installed on the computer when it accesses Stock-Trak websites – to display ads based on the computer’s past access to Stock-Trak websites. 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 http://optout.networkadvertising.org/.

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: www.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 (SSL), redundancy and annual security audits. Personal Information and other data of inactive users gets purged from our database after 24 months of inactivity for participants and after 48 months for instructors (for example: teachers and professors).

8. Opting Out of Changes To This Privacy Policy

From time to time, we may amend this Privacy Policy. Should any amendments create additional ways in which we may collect or disclose your Personal Information, you may opt out of those amendments by e-mailing us within 30 days of the posting of the revised Privacy Policy on the site. We will always identify the date this Privacy Policy was last revised at the top of the policy. It is your responsibility to monitor the policy periodically to determine whether there have been changes. Opting out of an amendment to this Privacy Policy may subject you to termination of your registration and participation in any ongoing or future contests at our sole discretion and upon notice to you.

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:

  1. The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
  2. The right of access; this is your right to see what data is held about you by a controller of your data.
  3. The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
  4. The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
  5. The right to restrict processing; this gives you the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
  6. The right to data portability; you have the right to ask for any data supplied directly to the controller of the data, to be provided in a structured, commonly used, and machine-readable format.
  7. The right to object; you have the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
  8. Rights in relation to automated decision making and profiling; you have the right not to be subject to a decision based solely on automated processing.

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

  • With your consent: We use the Personal Information you have provided us where you have given clear consent for the processing of your Personal Information for a specific purpose.
  • To comply with any legal or regulatory obligations (including in connection with a court order) and to protect and enforce Stock-Trak’s legal rights, interests and remedies to protect the business operations and customers of Stock-Trak or other persons.
  • To protect our legitimate interests: the processing is necessary for our legitimate business interests, unless there is a good reason to protect the individual’s Personal Information which overrides those legitimate interests. For example, we will use your Personal Information to provide you with the websites, products and services, customer support and service, for research and development purposes, and to protect your safety and security, including the monitoring of suspicious activity and fraud.

15. Resolving Complaints

If you have any concerns about the way Stock-Trak is handling you Personal Information, please let us know immediately. You may email us directly at privacy@stocktrack.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.
3575 Ashby Street

Montreal, Quebec, H4R2K3

Canada

Attention: Andrew Zeidel