Privacy Policy

Last Updated: June 23, 2023

Lendal Pro Technologies Inc. and its affiliates ("Lendal," "we," or "us") offers websites (the "Sites") and applications, browser extensions and other digital services that allow you to create and execute trading strategies (together with the Sites, the "Services").

The Privacy Policy describes how we handle the personal information we collect in connection with our Services, including how we collect, use, and share personal information, and the choices we offer that affect our use of personal information. This Privacy Policy applies to any Services provided by Lendal that link to this Privacy Policy.

Personal Information We Collect

We collect the following categories of personal information.

Account information. This includes your name, username, contact information (including email, phone number, and address), and any accounts you use to access the Services (such as your Discord account name and blockchain account address).
Trading and commercial information. We collect information about the Services you use, and the trading strategies you develop and execute using the Services. If you choose to link your TradingView account to the Services, we may access your account name and number to provide you the Services. We may also collect the account number, profit and loss, volume of trades, and account balances of any brokerage accounts you choose to connect to the Services.
Payment information. This includes your name, payment card information, billing information. We also collect crypto wallet address for blockchain based payments. Payment information is processed by our third-party payment processors in accordance with their privacy policies and terms of service. We do not have access to payment card numbers.
Communications that we exchange with you, including when you contact us with questions, feedback, or otherwise.
Marketing information. This includes your preferences for receiving communications about our Services and publications, and details about how you engage with our communications.

Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, such as:

Device data, such as your computer's or mobile device's operating system, manufacturer and model, browser type, IP address, unique identifiers, language settings, mobile device carrier, and general location information such as city, state or geographic area; and
Usage data, such as pages or screens you viewed, how long you spent on a page, browsing history, and access times, and page clicks, page scrolls, and page element interactions.

We may collect this information using cookies and other similar technologies. Cookies are text files that websites store on a visitor‘s device or in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, and helping us understand user activity and patterns. For more information on how you can control cookies, please see the Your Privacy Choices section below.

How We Use Personal Information

We use personal information for the following purposes:

To provide the Services. This includes administering your account on the Services; providing you with access to the Services, including to permit you to create and execute trading strategies; communicating with you and responding to any inquiries you may have; and analyzing your use of the Services to allow us to evaluate and improve the Services.

Research, development, benchmarking, and improving our Services. We may use personal information in support of our legitimate interests to analyze and improve the Services, identify trends, and operate and expand our business activities. We may also create aggregated, anonymized, or other de-identified statistics, which we may use for lawful business purposes, including for analytics, forecasting, and strategic planning.

Marketing and advertising, including for:

Direct marketing. We may send direct marketing communications, including, but not limited to, sending newsletters or publications, and notifying you of promotions, offers and events via postal mail, email, telephone, text message, and other means.
Interest-based advertising. We engage our advertising partners, including third party advertising companies and social media companies, to advertise our Services. For more information, or to understand your choices, please visit the Your Privacy Choices section below.

For compliance and protection, including to enforce any applicable terms and conditions, comply with legal obligations, defend against legal claims or disputes, protect the security and integrity of our Services, and identify and investigate fraudulent, harmful, unauthorized, unethical or illegal activity.

How We Share Personal Information

We may share personal information with:

Financial service providers that you connect to the Services. We may share information with financial service providers that you choose to connect to your account, in order to perform any operation you request through the Services. For example, if you connect your TradingView account to the Services, we may share trade instructions with TradingView to allow you to automatically execute your trading strategies.

Service providers. We share personal information with companies and individuals that provide services on our behalf or help us operate our Services or our business. These service providers include hosting services, communications, data and cyber security services, trading execution services, billing and payment processing services, fraud detection, investigation and prevention services, web and mobile analytics, email and communication distribution and monitoring services, and customer relation management systems.

Advertising partners. We may share personal information that we collect on our website with third party advertising companies (including for the interest-based advertising purposes described above), lead generation partners, and channel partners, resellers, and distributors that allow us to explore and pursue growth opportunities.

Professional advisors. We share personal information with professional advisors, such as lawyers, auditors, bankers and insurers, where necessary in the course of the professional services that they render to us.

Authorities and others. We may share personal information with law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate.

Business transferees. We may share personal information with acquirers and other relevant participants in business transactions (or negotiations for such transactions) involving a corporate divestiture, merger, consolidation, acquisition, reorganization, sale or other disposition of all or any portion of the business or assets of, or equity interests in, Lendal or our affiliates (including, in connection with a bankruptcy or similar proceedings).

Your Privacy Choices

Unsubscribe from direct marketing communications. You may opt out of marketing-related communications by following the opt out or unsubscribe instructions contained in the marketing communication we send you. You may continue to receive service-related and other non-marketing communications.

Access your account. You may access your personal information through your account on the Services. In some instances, you may also have the ability to correct personal information that is out of date or inaccurate, or to delete personal information that is no longer needed for a permitted purpose.

Personal information requests. We also offer you choices that affect how we handle the personal information that we control. Depending on your location and the nature of your interactions with our Services, you may request the following in relation to personal information:

Information about how we have collected and used personal information. We have made this information available to you without having to request it by including it in this Privacy Policy.
Access to a copy of the personal information that we have collected about you. Where applicable, we will provide the information in a portable, machine-readable, readily usable format.
Correction of personal information that is inaccurate or out of date.
Deletion of personal information that we no longer need to provide the Services or for other lawful purposes. You can delete your account in your account settings.
Withdrawal of consent, where we have collected and processed your personal information with your consent. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
Additional rights, such as to object to and request that we restrict our use of personal information.

To make a request, please contact us as provided in the "Contact us" section below. We may ask for specific information from you to help us confirm your identity. Depending on where you reside, you may be entitled to empower an authorized agent to submit requests on your behalf. We will require authorized agents to confirm their identity and authority, in accordance with applicable laws. You are entitled to exercise the rights described above free from discrimination.

In some instances, your choices may be limited, such as where fulfilling your request would impair the rights of others, our ability to provide a service you have requested, or our ability to comply with our legal obligations and enforce our legal rights. If you are not satisfied with how we address your request, you may submit a complaint by contacting us as provided in the "Contact us" section below. Depending on where you reside, you may have the right to complain to a data protection regulator where you live or work, or where you feel a violation has occurred.

Additional choices concerning data sharing. If you are based in the United States and choose to create an account for the Services, we provide additional information about how we share your information and your choices in relation to such sharing. Please visit our Consumer Privacy Notice below for further information.

Opt-out of interest-based advertising. You may limit online tracking by:

Blocking cookies in your browser. Most browsers let you remove or reject third-party cookies, including cookies used for interest-based advertising. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
Blocking advertising ID use in your mobile settings. Your mobile device settings may provide functionality to limit use of the advertising ID associated with your mobile device for interest-based advertising purposes.
Using privacy plug-ins or browsers. You can block our websites from setting cookies used for interest-based ads by using a browser with privacy features, like Brave, or installing browser plugins like Privacy Badger, Ghostery, or uBlock Origin, and configuring them to block third party cookies/trackers. You can also opt out of Google Analytics by downloading and installing the browser plug-in available at: https://tools.google.com/dlpage/gaoptout.
Platform opt outs. The following advertising partners offer opt out features that let you opt out of use of your information for interest-based advertising:
- Google: www.adsettings.google.com
- Facebook: https://www.facebook.com/about/ads
Advertising industry opt out tools. You can also use these opt out options to limit use of your information for interest-based advertising by participating companies:
- Digital Advertising Alliance for Websites: outout.aboutads.info
- Digital Advertising Alliance for Mobile Apps: https://youradchoices.com/appchoices
- Network Advertising Initiative: optout.networkadvertising.org

Note that because these opt out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.

Do Not Track. Some Internet browsers may be configured to send "Do Not Track" signals to the online services that you visit. We currently do not respond to "Do Not Track" or similar signals. To find out more about "Do Not Track," please visit http://www.allaboutdnt.com.

Data Security

We employ a number of technical, organizational and physical safeguards designed to protect the personal information we collect. However, no security measures are failsafe and we cannot guarantee the security of your personal information.

Data Storage and Retention

Our Services are operated from the United States. If you are located in another jurisdiction, please be aware that the information you provide to us may be transferred to, stored, and processed in the United States, which may not have equivalent privacy laws to those in the country where you reside or are a citizen.

We may retain your personal data for as long as it is reasonably needed in order to maintain and expand our relationship and provide you with our Services; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of such data, the potential, risk of harm from unauthorized use or disclosure of personal information, the purposes for which we process it, and the applicable legal requirements.

Children

Our Services are not intended for use by children. If we learn that we have collected personal information through our Services from a child without the consent of the child's parent or guardian as required by law, we will endeavor to delete it.

Changes to This Privacy Policy

We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via e-mail (if you have an account where we have your contact information) or another manner.

Contact Us

You can reach us by email at compliance@lendal.io following mailing address:

Lendal Pro Technologies Inc.

14175 W Indian School Rd, Ste B4-141

Goodyear Arizona 85395

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Consumer Privacy Notice

Reasons we can share your personal information	Does Lendal share?	Can you limit this sharing?
FACTS	WHAT DOES LENDAL Pro Technologies INC. ("LENDAL") DO WITH YOUR PERSONAL INFORMATION?
Why?	Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do.
What?	The types of personal information we collect and share depend on the product or service you have with us. This information can include: Your contact details Account transactions When you are no longer our customer, we continue to share your information as described in this notice.
How?	All financial companies need to share customers' personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers' personal information, the reasons Lendal chooses to share, and whether you can limit this sharing.
For our everyday business purposes - such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus	Yes	No
For our marketing purposes - to offer our products and services to you	Yes	No
For joint marketing with other financial companies	No	No
For our affiliates' everyday business purposes - information about your transactions and experiences	Yes	No
For our affiliates' everyday business purposes - information about your creditworthiness	No	No
For our affiliates to market to you	No	No
For nonaffiliates to market to you	No	No
To limit our sharing	Email us at compliance@lendal.io. Please note: If you are a new customer, we can begin sharing your information immediately from the date we post this notice. When you are no longer our customer, we continue to share your information as described in this notice. However, you can contact us at any time to limit our sharing.
Questions?	Email us at compliance@lendal.io.
Who we are
Who is providing this notice?	Lendal
What we do
How does Lendal protect my personal information?	To protect your personal information from unauthorized access and use, we use technical and organizational security measures.
How does Lendal collect my personal information?	We collect your personal information, for example, when you create an account or provide account information. We also may also collect your personal information from others, such as social media platforms, marketing partners and third-party data aggregators.
Why can't I limit all sharing?	Federal law gives you the right to limit only: sharing for affiliates' everyday business purposes - information about your credit worthiness, affiliates from using your information to market to you, and sharing for nonaffiliates to market to you. State laws and individual companies may give you additional rights to limit sharing.
What happens when I limit sharing for an account I hold jointly with someone else?	Your choices will apply to everyone on your account.
Definitions
Affiliates	Companies related by common ownership or control. They can be financial and nonfinancial companies.
Nonaffiliates	Companies not related by common ownership or control. They can be financial and nonfinancial companies. Lendal does not share with nonaffiliates so they can market to you.
Joint marketing	A formal agreement between nonaffiliated financial companies that together market financial products or services to you. We do not engage in joint marketing.
Other important information
Vermont: If you are consumer with a Vermont mailing address, we will not share information we collect about you with companies outside of Lendal unless the law allows. California: If you are a consumer with a California mailing address, we will not share information we collect about you with companies outside of Lendal unless the law allows.