Privacy Policy

Agreement

Tradewind Markets, Inc. (“TWM”) respects your privacy. We will never willfully disclose individually identifiable information about our customers to any third party, except in the limited circumstances permitted by this policy.

TWM does not sell, rent, or loan any personally identifiable information regarding its customers to any third party. Any information you give us is held with the utmost care, security, and will not be used in ways to which you have not consented.

This privacy policy (“Privacy Policy”) applies solely to information collected through the TWM websites, applications, widgets, blogs and their respective contents whether accessed via computer, mobile device or other. The Sites are offered by TWM, Inc. and its parent, subsidiary and affiliated companies, Site developers and other promotional partners (collectively, “TWM,” or “we”, “us”, “our”).

This Privacy Policy explains what information may be collected through the Sites, how such information may be used and/or shared with others, how we safeguard it and how you may access and control its use in connection with our marketing communications and activities. Please read this Privacy Policy carefully, because by using the Sites you are acknowledging that you understand and agree to the terms of this Privacy Policy.

  1. Information We Collect On Our Sites

    1. Information You Provide To Us

      • The Sites may ask you to provide information that could reasonably be used to contact you or to identify you personally (such as your name, e-mail address, telephone number, or home address (“Personal Information”)). For example, TWM may collect Personal Information when you register on the Sites, request information, submit comments or participate in some promotion, survey or other feature of the Sites, or otherwise communicate or interact with us. The Sites may also ask you to provide other information about yourself, such as demographic information (gender, zip code, age, etc.) or certain information about your preferences and interests. If we combine demographic or other information we collect about you with Personal Information about you, we will treat the combined information as Personal Information. To the extent the Sites allows you to apply to become a customer of TWM, additional information may be requested and collected from you via customer application forms and other forms. If you do not want your Personal Information collected, please do not submit it.

    2. Information We Collect Automatically

      • Whenever you visit or interact with the Sites, TWM, as well as any third-party advertisers and/or service providers, may use a variety of technologies that automatically or passively collect information about how the Sites are accessed and used (“Usage Information”). Usage Information may include, in part, browser type, operating system, the page served, the time, and the preceding page views. This statistical data provides us with information about the use of the Sites, such as how many visitors visit a specific page on the Sites, how long they stay on that page, and which hyperlinks, if any, they “click” on. This information helps us keep our website fresh and interesting to our visitors and tailor content to a visitor’s interests. Usage Information is generally non-identifying, but if TWM associates it with you as a specific and identifiable person, TWM treats it as Personal Information.
      • TWM also automatically collects your IP address or other unique identifier (“Device Identifier”) for the computer, mobile device, technology or other device (collectively, “Device”) you use to access the Sites. A Device Identifier is a number that is automatically assigned to your Device when you access a website or its servers, and our computers identify your Device by its Device Identifier.
      • The technologies used on the Sites to collect Usage Information, including Device Identifiers, may include, without limitation:

        1. Cookies

          • Cookies are data files placed on a Device when it is used to visit the Sites. TWM may place cookies or similar files on your Device for security purposes, to facilitate site navigation and to personalize your experience while visiting our Sites. Cookies allow us to collect technical and navigational information, such as browser type, time spent on our Sites and pages visited. Cookies also allow us to select which of our advertisements or offers are most likely to appeal to you and display them while you are on the Sites. If you would prefer not to accept cookies, you can change your browser settings to notify you when you receive a cookie, which lets you choose whether or not to accept it; or set your browser to automatically not accept any cookies. However, please be aware that some features and services on our Sites may not work properly because we may not be able to recognize and associate you with your TWM account(s).

        2. Pixel tags

          • A pixel tag is a transparent graphic image, sometimes called a web beacon or tracking beacon, placed on a web page or in an email, which indicates that a page or email has been viewed. In addition, a pixel tag may tell your browser to get content from another server. In order to ensure the safekeeping of your information, network advertising companies and publishers are not permitted to directly collect Personal Information on our Sites.
      • TWM may use Google Analytics and Google Display Network (DoubleClick). Google Analytics collects anonymous data about your interaction with our website via the DoubleClick cookie and through the standard Google Analytics implementation. Anonymous data may be used for purposes including delivering to you banner advertisements and other advertising tailored to your interests when you visit certain websites and selecting offers and products to display to you when you visit our website.

  2. How We Use The Information We Collect

    • TWM uses the information we collect about and from you for a variety of business purposes, including for example, to: respond to your questions and requests; provide you with access to certain areas and features of the Sites; verify your identity; communicate with you about your account and activities on the Sites and, in our discretion, changes to any TWM policy; tailor content, and features we serve you; improve the Sites and for internal business purposes; process applications and transactions; and for purposes disclosed at the time you provide your Personal Information or otherwise with your consent.

  3. Sharing Of Information

    • Except as provided in this Privacy Policy, we will not provide any of your Personal Information to any third parties without your specific consent. We may share non-Personal Information, such as aggregate user statistics, demographic information, and Usage Information with third parties. We may also share your information as disclosed at the time you provide your information, as set forth in this Privacy Policy and in the following circumstances:

      1. Third Parties Providing Services On Our Behalf

        • In order to carry out your requests, to make various features, services and materials available to you through the Sites, and to respond to your inquiries, we may share your Personal Information, or Usage Information with third parties that perform functions on our behalf (or on behalf of our partners), such as companies or individuals that: host or operate our Sites; analyze data; provide customer service; other third parties that participate in or administer our promotions or provide marketing assistance.

      2. Your Agreement To Have Your Personal Information Shared

        • While on our Sites, you may have the opportunity to opt-in to receive information and/or marketing offers from someone else or to otherwise consent to the sharing of your information with a third party. If you agree to have your Personal Information shared, your Personal Information will be disclosed to the third party and the Personal Information you disclose will be subject to the privacy policy and business practices of that third party.

      3. Business Transfers

        • We may share your Personal Information with the Royal Canadian Mint as needed to provide trading and recordkeeping services in connection with your TWM account.
        • Your Personal Information may also be used by us or shared with our subsidiaries, affiliates and other entities in the family of companies controlled by TWM, Inc. for internal reasons, primarily for business and operational purposes. As we continue to develop our business, we may sell or purchase assets. If another entity acquires us or all or substantially all of our assets, or assets related to the Sites, Personal Information, Usage Information, and any other information that we have collected about the users of the Sites may be disclosed to such entity as part of the due diligence process and will be transferred to such entity as one of the transferred assets. Also, if any bankruptcy or reorganization proceeding is brought by or against us, all such information may be considered an asset of ours and as such may be sold or transferred to third parties.

      4. Legal Disclosure

        • TWM may transfer and disclose information, including your Personal Information, Usage Information and Device Identifier (including IP address), to third parties to comply with a legal obligation; when we believe in good faith that the law requires it; at the request of governmental authorities conducting an investigation; to verify or enforce our User Agreement or other applicable policies; to respond to an emergency; or otherwise to protect the rights, property, safety, or security of third parties, visitors to our Sites or the public.

  4. Information We Receive From Third Parties

    • TWM may receive information about you from third parties. For example, if you are on another website and you opt-in to receive information from TWM, that website will forward to us your e-mail address and other information about you so that we may contact you as requested. You may also choose to participate in a third party application or feature through which you allow us to collect (or the third party to share) information about you, including Personal Information. In addition, we may receive information about you if other users of a third party website give us access to their profiles and you are one of their “connections” or information about you is otherwise accessible through your “connections” web page, profile page, or similar page on a social networking or other third party website or interactive service.
    • We may also supplement the information we collect about you through the Sites with outside records from third parties in order to enhance our ability to serve you, to tailor our content to you and to offer you opportunities to purchase products or services that we believe may be of interest to you. We may combine the information we receive from these third parties with information we collect through the Sites. In those cases, we will apply this Privacy Policy to any Personal Information received, unless we have disclosed otherwise.

  5. Your Choice And Access

    1. Opting Out

      • You may always direct us not to share your Personal Information with third parties, not to use your Personal Information to provide you with information or offers, or not to send you newsletters, e-mails or other communications by: (i) sending us an e-mail at compliance@tradewindmarkets.com with the word “Remove” as the subject header. Your opt-out request will be processed within 30 days of the date on which we receive it. Please be reminded that some emails sent by TWM are transactional in nature based on actions taken on our site, these are required by Federal law and cannot be unsubscribed from.
      • You can opt-out of Google Analytics for Display Advertising and customize Google Display Network ads using the Ads Preferences Manager .
      • You can find out more about how Google uses cookies in advertising and opt-out via the following links: Google Display Network (DoubleClick) & Google Analytics Opt-out Browser Add-on .
      • If you wish to verify, correct, or update any of your personal information collected through the Sites, you may edit your profile preferences or contact us at the above address or e-mail. In accordance with our routine record keeping, we may delete certain records that contain Personal Information you have submitted through the Sites. We are under no obligation to store such Personal Information indefinitely and disclaim any liability arising out of, or related to, the destruction of such Personal Information. In addition, you should be aware that it is not always possible to completely remove or delete all of your information from our databases without some residual data because of backups and other legal or compliance reasons.

    2. Do Not Track Signals

      • California law requires us to let you know how we respond to web browser Do Not Track (DNT) signals. Because there currently is not an industry or legal standard for recognizing or honoring DNT signals, we do not respond to them at this time. We await the result of work by the privacy community and industry to determine when such a response is appropriate and what form it should take.

    3. Information Security

      • We use certain reasonable security measures to help protect your Personal Information, however, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the website and provide us with your information at your own risk.

  6. Children

    • The Sites are not directed to children under 13. We do not knowingly collect personally identifiable information from anyone under 13 years of age. If we determine upon collection that a user is under this age, we will not use or maintain his/her Personal Information without the parent/guardian’s consent. If we become aware that we have unknowingly collected personally identifiable information from a child under the age of 13, we will make reasonable efforts to delete such information from our records.

  7. Security Of Your Information

    • We use certain reasonable security measures to help protect your Personal Information. However, no electronic data transmission or storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure or warrant the security of any information you transmit to us, and you use the Sites and provide us with your information at your own risk.

  8. Retaining Personal Information

    • We retain information about you as long as necessary to provide our services or to comply with applicable law. We retain information about you after you deactivate your account, consistent with applicable law, legal process, or governmental request, to detect or prevent fraud, to collect fees owed, to resolve disputes, to address problems with our Services, to assist with investigations, or to enforce our user agreement or other applicable agreements or policies.

  9. Changes

    • Please note, we may change information on the website and/or this Privacy Policy, at any time without prior notice to you, and any changes will be effective immediately upon the posting of the revised Privacy Policy on the website.
    • We urge you to keep any password that you establish with us in a safe place and not to divulge it to anyone. Also remember to log off your account and close your browser window when you have finished your visit. This is to ensure that others cannot access your account, especially if you are sharing a computer with someone else or are using a computer in a public place.

  10. Contact Us

We use cookies and similar technologies to improve and customize our services. By using Tradewind Markets’ website, you agree to accept our policy. To learn more, view our Privacy Policy