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Privacy Policy

This Privacy Policy describes how SurgeTrader LLC (the “Company,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information. This Privacy Policy also tells you about your rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.

You can jump to particular topics by going to the headings below:

Information We Collect

How We Use Information

How We Disclose Information

Your Choices

How We Protect Information

How Long We Retain Information

Transmission Of Information To Other Countries

Third-Party Applications/Websites

Changes To This Privacy Policy

Contact Information

Additional Information For California Residents

Information We Collect

We collect information about you in a variety of ways depending on how you interact with us and our websites, products, and services (collectively, the “Services”), including:

  • Directly from you when you provide it to us, such as when you register for an account, sign up to receive communications from us, or contact us by phone, email, or otherwise.
  • Automatically through the use of cookies, server logs, and other similar technologies when you interact with our Services.
  • From other sources, including, for example, our affiliates, business partners, service providers, online social media networks, and other third parties, or from publicly available sources.

The following provides examples of the type of information that we collect in a variety of contexts and how we use that information.

Context Types of Personal Information Primary Purpose for Collection
and Use of Personal Information
Account Registration When you register for an account, we collect your name, username and password, date of birth, and email address. We also collect information relating to the actions that you perform while logged into your account. We have a legitimate interest in providing account related functionalities to our users.
Affiliate Program If you sign up for Surge Trader Affiliate Program, we collect your name, email address, date or birth, phone number, and address. We may also collect optional information, such as information about your website, YouTube Channel or Social Media Page. We have a legitimate interest in administering our Affiliate Program.
Cookies and Similar Tracking Technologies

We use technology to monitor how you interact with our Services. This may include which links you click on, or information that you type into our online forms. Some of these technologies may use “cookies.” Cookies are small pieces of information that a website sends to a computer’s hard drive while a website is viewed. Other types of data we track include your IP address, the website that referred you to our website, and data about the device you use to visit our website.

We also allow third parties to place technology on our websites (e.g., a cookie or a pixel) that allows them to track you.  The third party might also collect data over time and across other websites.  They use this data to serve advertisements tailored to your interests, which may include advertisements about our products or services.

For more information, please refer to the “Cookies Settings” link in our website footer.

We have a legitimate interest in making our Services operate efficiently, understanding how you interact with our Services and detecting and preventing fraud.

Where required by law, we base the use of third-party tracking technologies upon consent.

Inquiries, Comments, and Feedback If you contact us, we collect your name and contact information, as well as any other content that you send to us. We have a legitimate interest in receiving, responding to, and following up on your comments, inquiries, feedback or requests.
Interactions with Our Services When you access or utilize our Services, our servers automatically gather certain information and store it in log files. This information may include details like your IP address, device information, browser type and settings, and information about your activities within the Services (such as timestamps of usage, pages/files viewed, searches performed, and other actions like feature usage), and device event information (such as system activity, error reports, and hardware configurations), depending on your interaction with us. We have a legitimate interest in understanding how you interact with our Services to better improve them, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud and performing diagnostics.
Mailing List When you sign up to receive our newsletter or other communications from us, we collect your email address and phone number (where applicable). Where required by law, we share information about our products and services with individuals that consent to receive such information. We also have a legitimate interest in sharing information about our products or services.
Purchases In case of any purchases, we collect information necessary to process your payment, such as the payment instrument number and security code linked to your payment method and your billing address. We use your information to perform our contract to provide you with products or services.

If you are located in Canada, our lawful basis for processing your personal information is generally consent. If you would like specific information about our lawful basis of processing, please contact us as indicated in the “Contact Us” section below.

How We Use Information

In addition to the purposes and uses described above, we use information in the following ways:

  • To identify you when you visit our Services.
  • To improve our Services.
  • To conduct analytics.
  • To communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback.
  • To send marketing and promotional materials including information relating to our products, services, sales, or promotions, or those of our business partners.
  • To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of our company and our users, employees, or others.
  • To debug, identify and repair errors that impair existing intended functionality of our Services.
  • To comply with our legal or regulatory obligations, to establish or exercise our rights, and to defend against a legal claim.
  • For internal administrative purposes, as well as to manage our relationships.
  • For such other purposes as you may consent (from time to time).

Although the sections above describe our primary purpose in processing your information, in many situations we have more than one purpose. For example, if you complete an online purchase, we may collect your information to perform our contract with you, but we also collect your information as we have a legitimate interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your purchase. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our legitimate interest in conducting our business.

How We Disclose Information

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:

  • Affiliates and Acquisitions. We may share information with our corporate affiliates (g., parent company, sister companies, subsidiaries, joint ventures, or other companies under common control). If another company acquires, or plans to acquire, our company, business, or our assets, we will also share information with that company, including at the negotiation stage.
  • Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the shipment of products to or the provision of services by a third-party intermediary.
  • Service Providers. We share your information with service providers. Among other things service providers help us to administer our website, provide technical support, process payments, and assist in the fulfillment of orders.
  • Other Disclosures with Your Consent. We may disclose your information to other third parties when we have your consent or direction to do so.

Your Choices

Some jurisdictions give you a right to make the following choices regarding your personal information:

  • Access To Your Personal Information. You may request access to your personal information or confirmation that we have information about you. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format.
  • Changes To Your Personal Information. We rely on you to update and correct your personal information. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.
  • Deletion Of Your Personal Information. You may request that we delete your personal information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes.
  • Opt-out of Targeted Advertising. You may opt-out of online tracking based targeted advertising (e.g., cookies) by clicking the Cookie Settings link here or the “Do Not Share” link on our homepage. Please note that if you change browsers or devices, or if you clear your browser’s cache, you may need to click the link again to apply your preference. [You may also opt-out of other forms of targeted advertising by submitting a request as described below.] We also recognize Global Privacy Control (GPC) signals enabled by customers on their web browser or web browser extension as valid opt-out requests where required by applicable law. Please note that your opt-out preference signal will be applied only to your current browser and device. For more information about GPC, please visit Global Privacy Control.
  • Objection to or Restriction of Certain Processing. In certain circumstances, you may object to the processing of your personal information, or request that we restrict processing of your personal information, by following the instructions described below.
  • Revocation Of Consent. Where we process your personal information based upon consent, you may revoke consent. Please note, if you revoke your consent for the processing of personal information then we may no longer be able to provide you services.
  • Online Tracking. We do not currently recognize the “Do Not Track” signal.
  • Promotional Emails. You can stop receiving our marketing and promotional emails by following the unsubscribe instructions in emails that you receive from us. If you decide not to receive marketing or promotional emails, we may still send you non-marketing communications such as service-related updates, account administration, responding to your service requests, etc.
  • Promotional Text Messages. If you receive a text message from us that contains promotional information you can opt-out of receiving future text messages by replying “STOP.”
  • Account Information. To review or change information in your account or close it, follow these steps: (1) Log in to your account settings and update your user account or (2) Contact us using the provided contact information. Note: Upon request, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files for fraud prevention, problem resolution, investigations, enforcement of legal terms, and compliance with legal requirements.

Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. We will not discriminate against individuals who exercise their privacy rights under applicable law.

Submitting Requests

To submit a request to exercise the rights described above, please contact us via email at [email protected], call our toll-free number at 866-998-7652, go to https://surgetrader.com/contact/, or refer to the information at the bottom of this document.

In order to process your request, we must be able to verify your identity to make sure you are the person about whom we have collected personal information or an authorized representative. Depending on the type of request, we may conduct the verification process by email or phone using information that matches our records. The information you must provide as part of the verification process may include: name, contact information (such as email address or phone number), relationship with us, and residency. We may also ask for additional information as needed based on your relationship with us.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. To do so, you must (1) provide that authorized agent written, signed, and notarized permission to submit such request, and (2) verify your own identity directly with us.

If you are an authorized agent submitting a request on behalf of an individual, you must provide written and notarized proof that you have been authorized by the individual to act on his or her behalf. Please note, we may deny a request from an authorized agent that does not submit proof that they have been authorized to submit such request.

How We Protect Information

No method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

How Long We Retain Information

We retain your personal information for only as long as necessary to fulfil the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.

Transmission Of Information To Other Countries

By submitting your personal information to us you agree to the transfer, storage, and processing of your information in a country other than your country of residence including, but not necessarily limited to, the United States. If you would like more information concerning our attempts to apply the privacy principles applicable in one jurisdiction to data when it goes to another jurisdiction you can contact us using the contact information below.

Third-Party Applications/Websites

For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices websites, or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about such third party’s privacy practices.

Changes To This Privacy Policy

We may update our Privacy Policy from time to time to reflect changes to our practices, technology, legal requirements and other factors. When changes are made to this Privacy Policy, they will become immediately effective when published. You can check the “Last Updated” legend at the bottom of this page to see when this Privacy Policy was last revised.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices, or if you need to access this Privacy Policy in an alternative format due to having a disability, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

Email: [email protected]

Mail: SurgeTrader LLC 4851 Tamiami Trail N, Suite 200 Naples, FL 34103 United States

If you are not satisfied with our response, and are in the European Union or United Kingdom, you may have a right to lodge a complaint with your local supervisory authority.

Additional Information For California Residents

California law requires us to disclose the following additional information related to our privacy practices. If you are a California resident, the following privacy disclosures apply to you in addition to the rest of the Privacy Policy.

  • California Shine the Light. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the “Contact Information” section above.
  • Categories of Information We Collect, Use, and Disclose. The table below describes the categories of personal information we collect, disclose for a business purpose, and/or “share” for purpose of cross-context behavioral advertising. Please note, in addition to the recipients identified below, we may disclose any of the categories of personal information we collect with government entities, as may be needed to comply with law or prevent illegal activity. We do not “sell” your personal information for money. As discussed elsewhere in the Privacy Policy, we use cookies and similar tracking technologies for purposes of targeted advertising.
Category of Personal Information Category of Recipients  
Disclosures for a Business Purpose Sharing for Cross-Context Behavioral Advertising
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.

·    Affiliates or subsidiaries

·    Business partners

·    Data analytics providers

·    Internet service providers

·    Joint marketing partners

·    Operating systems and platforms

·    Other Service Providers

·    Payment processors and financial institutions

·    Professional services organizations, this may include auditors and law firms

·    Social networks

·             Advertising networks
Government Issued Identification – this may include social security number, driver’s license number, or state issued identification number, passport number.    
Financial Information – this may include bank account number, credit card number, debit card number, and other financial information.    
Health Related Information – this may include medical information, mental or physical condition or treatment, or health insurance information.    
Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical, or mental handicap, etc.    
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.    
Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.    
Geolocation data    
Audio, electronic, visual, thermal, olfactory, or similar information    
Inferences drawn from any of the information listed above    

 

  • California Sensitive Information Disclosure. We collect the following categories of sensitive personal information (as defined under California law): account log-in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account. This information is collected in order to process transactions, comply with laws, manage our business, or provide you with Services. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.

 

Last Updated and Effective: February 13, 2024

FUNDED ACCOUNT DISCLAIMER

Hypothetical performance results do not represent actual trading and are generally designed with the benefit of hindsight, which may under- or over-compensate for the impact of certain market factors, including lack of liquidity and price slippage. Furthermore, since hypothetical trading does not involve financial risk, no hypothetical performance results can completely account for the impact of certain factors associated with risk, including the ability of the customer or the advisor to withstand losses or to adhere to a particular trading program in the face of trading losses.

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Invitations to participate in the May contest will be sent out by email and SMS,
or you may revisit the site to sign up in early May.

 

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