Shamrock Trading Corporation (“STC”) values our customers, their information, privacy and trust.  This Policy explains how we collect, use and protect your information through our websites and mobile applications. Specifically, this Policy applies to STC’ collection, use, storage, and transfer of information associated with STC’ site, www.shamrocktradingcorp.com and affiliated sites (collectively, “Sites”). If there is something you do not understand about our privacy practices, please feel free to contact us at legalnotices@shamrocktradingcorp.com.    

Throughout this Policy, we refer to the term “Personal Information”. “Personal Information” is data about an individual who can be identified from that data, or by combining it with other data.  Personal Information is usually your name in combination with another identifier, such as date of birth, postal address, email address, telephone number, or government-issued identification number.  The specific definition of Personal Information varies from one jurisdiction to another. 

Personal Information does not include anonymous or aggregated data that can no longer be used to identify a specific person, even if combined with other data.

Many of our customers are businesses, rather than individuals.  We do not consider Business Information, such as one’s position, business name, title, business email, business phone number, business address, business fax, and other similar business information, to be Personal Information.

Information We Collect

Information Collected Directly From You

We may collect your first name, your company, your email address, phone number and monthly business volume when you sign up to receive information about our products or services, request a price quote, or voluntarily submit other information to us. We use this information to provide the requested information.

When you report a problem with our Sites or services, we will collect your name, email address, and phone number, along with a description of your problem so that we may address your problem. When you contact us via the company email address, we will collect your email address and any information you include in your email to similarly address your concerns.

We collect your name, address, phone number, and email address when you create an account on our Sites. When you register for using any application, we collect your name, address, email address, phone number, your unique account ID, as well as information about your business such as your company’s name, company size, and business type. We use this information to confirm your registration initially and to confirm your identity when you later log in to your account. We also use this information to confirm your registration, respond to customer service requests, administer your account, improve the operation of our application, improve the operation of our Sites and application, conduct research and analysis of how our customers use our Sites and mobile application, and assess which of our products and services may be of interest to you. We will keep this information for as long as you have an account with us to allow us to verify your identity and to provide you with the account information you request. In addition, we may retain Personal Information from closed accounts to comply with national laws, prevent fraud, collect any moneys owed, resolve disputes, troubleshoot problems, assist with any investigation, enforce our Terms of Use or contractual rights, and take other reasonable actions permitted or required by applicable law.

In the absence of a legal obligation to the contrary, we keep your contact information for a year after your last contact with us. 

Our Sites are not directed to children under age 13 and we do not knowingly collect Personal Information from children under the age of 13.  Children under 13 should not provide their Personal Information to us through our Sites, to customer service, or in writing.  If we learn that Personal Information belonging to anyone under the age of 13 is stored on the Sites, we will immediately delete such information and refrain from using it for any purpose.

Other Information We Collect

In addition to collecting information directly from you as described in the previous section, we also  automatically gather information when you browse or view our Sites or use our mobile application. For the Sites, this information may include Internet Protocol (IP) address, browser type and language, Internet service provider (ISP), referring and exit websites and applications, operating system, date/time stamp, clickstream data, and other information related to your visit. This information may include the type of phone or other mobile device you are using, the duration and frequency of your usage sessions, information regarding application crashes and screens you chose to view, gestures (i.e., taps, swipes, pinches, etc.) you use on the application, whether you are a first-time or a returning user, links you clicked on while in the application, and your flow and navigation path through the application. 

We use this browsing information to make sure that the Sites and applications, and their associated parts, are functioning properly, that the Sites and applications are displayed properly for your equipment and software, and that we can provide you with information useful to your location. 

There are “do not track” or similar browser choices available to internet users with respect to online web activity, but given the present lack of consensus of what constitutes an informed election, appropriate trigger or breadth of scope of such choice, our Sites will not operate any differently when a “do not track” signal is received.

In some of our email messages, you will find a “click-through URL” linked to content on our Sites.  We track this click-through data to help us determine interest in particular topics and measure the effectiveness of our customer communications. If you prefer not to be tracked in this way, you should not click such links in our email messages.

Cookies

We use technologies such as “cookies” so we can remember certain information about you, remember your preferences or recognize you when you return.  They also help us compile aggregate data about Site traffic and Site interaction so that we can improve our Sites and protect our Sites from fraud.

A cookie is a text file that stored on your computer.  As text files, cookies cannot read information on your hard drive, run programs or deliver viruses to your computer.  

Most browsers are set to accept cookies automatically. You can set your browser to decline all cookies automatically or to prompt you for a response each time a cookie is offered. If you decline cookies, you may find that you cannot access all of our Site’s features.

During your browsing session, we use “session” cookies to store information and monitor Site function.  For thirty minutes after your session, a cookie tracks the number of visitors to our Sites.  Until midnight of the day after your last session, a cookie tracks the number of times you visit the Sites.  For two weeks after your last session, a cookie retains the items you have place in the Sites’ cart, in case you leave without purchasing and then return to make the purchase.  There is a permanent cookie used to remember your password. 

Web beacons, also known as clear GIFs, are often used in combination with cookies. Often transparent, these images are part of web pages, and allow us to count users who have visited certain pages and to generate statistics about how our Sites are used. They are not used to access Personal Information. 

We also use log files when you visit our Sites. Log files track IP addresses, browser type, Internet Service Provider (ISP) identity, referring/exit pages, platform type, date/time stamp, and number of clicks. We utilize this information to analyze trends, administer the Sites and applications, prevent fraud, track website navigation in the aggregate, and gather broad demographic information for aggregate use.

Pixel tags enable us to send email messages in a format customers can read, and they tell us whether mail has been opened. We may use this information to reduce or eliminate messages sent to customers. 

Google Adwords, Google Analytics, and Appsee

We use Google Adwords and Google Analytics in connection with our Sites to gather data such as age, gender and interests to provide advertising targeted to suit your interests and preferences.

Google Adwords and similar programs from other companies help us target our online ads based on information collected directly from you or by automated means, like cookies. These companies also use automated technologies to collect information when you click on our ads, which helps track and manage the effectiveness of our marketing efforts.  

You may opt out of the automated collection of information by third-party ad networks for the purpose of delivering advertisements tailored to your interests, by visiting the consumer opt-out page for the Self-Regulatory Principles for Online Behavioral Advertising at http://www.aboutads.info/choices/ and edit or opt-out your Google Display Network ads’ preferences at http://www.google.com/ads/preferences/  

Google Analytics collects anonymous information that is not used to identify a particular user.  This information helps us better understand how visitors use our Sites, detect and defend against fraud and other security risks, and present advertisements, products, and/or services of interest to you.

To learn more about how Google Analytics collects and processes data, please visit “How Google uses data when you use our partners’ sites or apps”, located at www.google.com/policies/privacy/partners/. To learn about how to opt-out of Google Analytics, please visit http://tools.Google.com/dlpage/gaoptout/.

We may use Appsee Analytics Service in connection with our mobile applications to gather data about your use of the mobile application. Appsee does not collect any Personal Information during your use of the application. Appsee does not track your activities on applications that do not use Appsee. For more information, see the Appsee Privacy Policy (www.appsee.com/legal/privacypolicy) for information collected by Appsee Analytics Service. We use the information collected by Appsee Analytics Service to improve your experience and ensure that it provides you with an optimal customer experience.

Location

You may give consent for our Sites to capture and record certain precise geo-location or global positioning data from your device in order to tailor information to your location. We may link such location data to other information that you provide to us or that may be accessed in connection with your use of our Sites. You should be able manage how your mobile device and mobile browser share location information with us, as well as how your mobile browser handles cookies and related technologies, by adjusting your mobile device’s privacy and security settings. 

Use of Your Personal Information

We use your Personal Information to further legitimate business interests – to transact business with you and serve you as a customer. As described above, we use your Personal Information to enable you to participate in online transactions, confirm your registration with the Sites and applications, send you requested information, administer your account, personalize content so that it applies to you and your interests, compile, analyze, and do research on our user’s demographics and behavior, and detect, investigate, and prevent activities that may violate our policies or be illegal. We may also use your Personal Information to communicate with you about products and services we believe you might find of interest and to administer promotions, surveys, contests and sweepstakes in which you might participate.

We also use the information automatically collected about you during your use of the Sites and applications, as described above, to improve the effectiveness of our website, operations, mobile experience, or marketing efforts or as described elsewhere in this policy, to prevent against fraud and theft, and otherwise to protect our Sites’ visitors and our business.

Our employees and agents may view your Personal Information to perform their jobs and service your needs. We authorize access to your Personal Information to them on a need-to-know basis to provide you with our products or services to you, or for one of the other reasons listed in this section.

Sharing Your Personal Information

As a general rule, we will not disclose any of your Personal Information except when we have your permission or under special circumstances, such as when we believe in good faith that the law requires it or under the circumstances described in this Policy. For instance, we may share your Personal Information in the following circumstances:

We may provide your personal information to affiliated companies or others who help us operate the Sites or application or assess your interest or satisfaction with the Sites, application, or our products. When we do so, we will ensure that such affiliated companies are contractually prohibited from using that information for any other reason.

We may share your Personal Information with third parties who may help us operate the Sites or help us assess your interest or satisfaction with the Sites.

We may disclose your Personal Information if we determine that disclosure is reasonably necessary to enforce our Terms of Use, this Privacy Policy or to otherwise protect our operations, clients or users.

We may release your Personal Information to others (including law enforcement) if we believe such release is reasonably necessary to comply with the law or legal process; enforce or apply the terms of applicable terms of use; detect, prevent, or otherwise address fraud, security or technical issues; or otherwise protect the rights, property or safety of others.

We may sell, transfer and/or disclose your Personal Information as part of a business divestiture, sale, merger, or acquisition of all or a part of our business.  If another company acquires our company, business, or assets, that company will possess the Personal Information collected by us and will assume the rights and obligations regarding your Personal Information as described in this Privacy Policy.  In the event of an insolvency, bankruptcy, or receivership, your Personal Information may also be transferred as a business asset.

In addition, we may share aggregate, non-individual information, incapable of identifying a particular person, with third parties for lawful purposes.

California Privacy Rights

California Civil Code Section 1798.83 permits users of our website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e‐mail to legalnotices@shamrocktradingcorp.com, or write us at 9300 Metcalf Avenue, Overland Park, KS 66212.

If you are a California resident under the age of 18, and a registered user of any site where this policy is posted, California Business and Professions Code Section 22581 permits you to request and obtain removal of content or information you have publicly posted. To make such a request, please send an email with a detailed description of the specific content or information to legalnotices@shamrocktradingcorp.com. Please be aware that such a request does not ensure complete or comprehensive removal of the content or information you have posted and that there may be circumstances in which the law does not require or allow removal even if requested.

Links to Other Websites

You may be able to post content to Social Networking sites (such as Facebook, Linked-In, Twitter, and Google+) on which we maintain a presence. If you choose to do this, we will provide information to the Social Networking sites, and receive information from them, in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policies. We are not responsible for the availability, accuracy, content, products or services of such Social Network sites.

While you are using the Sites or application, you may be linked or directed to other third-party sites outside of our Sites that are beyond our control.  Each of these third-party sites may have a privacy policy different from ours.  Please carefully review the privacy policies of these sites.  We are not responsible for any actions or policies of such third parties.

Data Movement

We may maintain your Personal Information on computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

We process data, including Personal Information, in the United States.  We do not transfer your Personal Information to another organization or a country absent the existence of adequate security and privacy controls.  We transfer Personal Information to the United States only with your consent or to perform a contract with you, and consistent with the practices described in this Privacy Notice. We do not collect or store sensitive information about you.

Security Measures

We maintain a variety of industry-standard security measures, including physical, electronic and procedural safeguards. For instance, we use SSL encryption technology for all credit card numbers, bank account numbers, passwords, and registration information you provide us. No system can be completely secure, so we do not promise, and you should not expect, that your Personal Information, searches, or other communications will always remain secure.

Your Access and Consent to Use of your Personal Information

If you believe that the Personal Information that we have collected about you is incomplete, inaccurate, or not up to date, or if you would like to review and/or request changes or deletion of that information, you can contact the Legal Department at the address noted below.

If you do not consent or want to withdraw your consent for us to collect, use, or disclose your Personal Information as described in this Policy, please contact the Legal Department at the address noted below. In your request, please identify the Personal Information at issue and the collection, use, or disclosure you wish to stop.

Denying or withdrawing consent may not allow us to provide you with some or all of the products, services, or information you request.

You may opt-out of receiving marketing-related emails by clicking the "unsubscribe" link at the bottom of any email you receive from us. If you are having difficulty unsubscribing from our marketing communications, please contact us at legalnotices@shamrocktradingcorp.com.

If you opt-out from receiving marketing emails or text messages, we may still need to send you communications about your, orders, customer service inquiries, and other matters.

If you agreed to receive future marketing communications directly from a third party through our Sites or application, you will need to contact that party to opt-out of such communications. This process may be outlined on that party's privacy policy.

Changes to this Privacy Policy

We reserve the right to modify this Privacy Policy at any time.  Changes and clarifications will take effect immediately upon their posting on the Sites and in connection with the downloading of the application, and we will change the “Last Modified” date below.

Questions and Contact Information

If you would like to access, correct, amend or delete any personal information we have about you, register a complaint, or simply want more information, you may contact our Legal Department at:

9300 Metcalf Avenue
Overland Park, KS 66212
legalnotices@shamrocktradingcorp.com

Last Modified: September 12, 2018