Privacy Policy

1. SCOPE

1.1. Data Protection guidelines


This privacy policy (this "Privacy Policy") applies to information we collect or use on websites and mobile applications, including www.easyquant.io products, features, services, or portions thereof (collectively, the "Service") owned or controlled by EasyQuant Corporation or its affiliates ("EasyQuant" or "we" or "our" or "us"). Affiliates are entities that control, are controlled by, or are under common control with us.


1.2. Changes to the privacy policy


Although most changes are likely to be minor, we may change our Privacy Policy from time to time, and in our sole discretion. We encourage our visitors to periodically check this page for changes to the Privacy Policy. Your continued use of the Service following a change to the Privacy Policy constitutes your acceptance of those changes. The date of the last revision to the Privacy Policy is indicated at the top of the page. You are responsible for ensuring that we have a current, active, and deliverable email address for you and for periodically visiting this Privacy Policy to learn of any changes.


1.3. Conditions for services


This Privacy Policy, the Terms of Use (the "Terms of Use"), the Platform Services Agreement, and the Subscription and Sublicense Agreement, all of which are incorporated herein by reference, are an agreement (collectively, the "Agreement") between you ("you" or "your" or "you"), a user of the Service, and us. By accessing or using the Service, you acknowledge and agree to this Agreement. If you do not agree to this Agreement, you may not use the Service.


1.4. Third-party links


The Service contains links to other third-party websites or services. Please note that we are not responsible for the content or privacy practices of such third party websites or services. We encourage our users to be aware when they leave the Service and to read the privacy statements of any other sites that collect personally identifiable information. When you use the Service or its content, certain third parties may use automated data collection technologies to collect information about you or your device. These third parties may include:

• Advertisers, ad networks and ad servers;
• Analysis companies;
• Manufacturer of your mobile device;
• Your mobile service provider;


These third parties may use tracking technologies to collect information about you when you use the Service. The information they collect may be linked to your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites, apps, and other online services. They may use this information to deliver interest-based (behavioral) advertising or other targeted content to you.

We have no control over the tracking technologies of these third parties or how they are used. If you have questions about an advertisement or other targeted content, you should contact the relevant provider directly.

2. WHAT WE COLLECT

2.1. Information provided by you


We may collect information that identifies you ("Personal Information") when you use the Service or register for an account. The types of Personal Data we may collect include:

Identity data includes first name, last name, username or similar identifier, title, date of birth, and gender.

Contact details include email address and phone numbers when requesting services via SMS.

Financial data includes bank account and payment card data.

Transaction Data includes details about payments to and from you and other details about products and services you have purchased from us.

Technical data includes IP address, your login information, browser type and version, time zone setting and location, browser plugin types and versions, operating system and platform, and other technologies on the devices you use to access this website.

Profile data includes your username and password, purchases or orders you have made, your interests, preferences, algorithm code, backtests, compilation activities, feedback, and survey responses.

Usage data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences regarding receiving marketing from us and our third parties and your communications preferences.


We receive information about you in several ways:


Information You Give Us. We collect information that you provide directly to us as part of the Service in a variety of ways, including, but not limited to, when you register for an account; purchase a product or service; enter a sweepstakes, contest, rewards program, or other promotion; use the Service to upload, share, or submit content or information; publicly post information through links to social networking sites, forums, blogs, message boards, chat rooms, or similar features; and when you request customer service or provide feedback or survey responses.

Information we receive from others. We may receive information about you from other sources, such as Facebook, Twitter, Instagram, or other social media properties. Other users of the Service, including but not limited to Marketplace users. We may add this to the information we receive from the Service.


Automatically collected information:


A. Traffic and usage information generated when you visit the Service, including traffic data, logs, pages you visit, your device's unique device identifier, mobile network, browser information, operating system, IP address, cookie information, the type of device you use to access the Service, and any other communications data resulting from your access to and use of the Service;

B. In connection with your visit to or use of the Service, we may automatically collect information about our users, such as the number and frequency of users and their characteristics, as well as information about similar user groups, certain age groups, or users living in a particular geographic area. This data is used only in the aggregate as a statistical measure and not in a way that would identify you personally. Aggregate information is generally collected through the use of cookies and beacons;

C. Information from public databases and third parties;

D. When you access or use the Service or any part thereof, we may collect physical location information that is sufficiently accurate to locate a particular person or device ("Location Information"). We collect Location Information only with your consent (for example, if you agree to provide it to us after you first access or use the Service). We may use Location Information and share it with third parties to provide you with content and services relevant to a particular location, such as advertising, search results, and directions;

E. The service can access metadata and other information associated with other files stored on your device. This may include photos, audio and video clips, personal contacts, and address book information.

If you do not want us to collect this information, do not download or delete the service from your device. We may also use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).

3. TRACKING TECHNOLOGIES


We may use one or more of the following tracking technologies and similar future tracking technologies to automatically collect information: Cookies, Local Shared Objects, Web Beacons, Unique Phone Numbers, General Log Information, and Referral Information from Third Party Services.


Cookies
We may log information using "cookies". Cookies are small data files that are stored on your hard drive by a website. We may use both session cookies (which expire when you close your web browser) and persistent cookies (which remain on your computer until you delete them) to provide you with a more personalized and interactive experience with the Service. This type of information is collected to make the Service more useful to you and to tailor your experience with us to your specific interests and needs.

Web Beacons
Web beacons, also known as Internet tags, pixel tags, single-pixel GIFs, or clear GIFs, link web pages to web servers and their cookies. Web beacons may be embedded in web pages, videos, or emails to collect certain types of information from your browser, verify that you have viewed a particular web page or email message, and determine, among other things, the time and date you viewed the content, the IP address of your computer, and the URL of the web page from which the content was viewed.


Local Shared Objects
Local Shared Objects, sometimes known as Flash cookies, can be used to store your preferences or display content based on what you have viewed on different websites to personalize your visit.


"Ad IDs" and other in-app tracking methods

There are a variety of tracking technologies that may be included in mobile applications. These are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers or other identifiers such as "Ad IDs" to associate app user activity with a particular app.


Google Analytics
We use Google Analytics ("Google Analytics"), a web analytics service provided by Google, Inc ("Google"). Google Analytics uses "cookies". The information generated by the cookies about your use of the service (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the service, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. Google will not associate your IP address with any other data held by Google. You can refuse the use of cookies by selecting the appropriate settings on your browser. However, please note that in this case you may not be able to use all the features of the service. For more information on how to refuse the use of cookies, please see Section 6 (Do Not Track Disclosures) below. By using the service, you consent to the processing of data about you by Google in the manner and for the purposes set out above.

4. USE OF PERSONAL DATA


We use your personal information as follows:

To provide, operate, maintain, improve and promote the Service and any other information, products or services you request from us.

To allow you to access and use the Service, including uploading, downloading, collaborating and sharing content, photos, images, videos and information with other users or third parties.

To process, verify and complete transactions and send you related information, including purchase confirmations and invoices, to fulfill our obligations and enforce our rights arising from contracts entered into between you and us, including billing, collection and enforcement, and to build a user database.

To send transactional messages, including responding to your comments, questions, and requests; to provide customer service and support; to send technical notices, updates, security alerts, and support and administrative messages; and, when we have location information, we use it to customize our service to you and others.

To process and provide contest entries and rewards.

To send information such as confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.

To inform you of promotions, upcoming events and other news about products and services offered by us and our selected partners.

To monitor and analyze trends, usage and activity in connection with the Service and for marketing, promotional, administrative, analytical, research, optimization and other purposes. For example, we may use statistical analysis of usage data to measure interest in various areas of the Service, for development purposes, and to inform advertisers and partners in aggregate and anonymous form about consumers who click on their advertisements or other messages. IP addresses are also used for system administration and troubleshooting.

To link or combine user information with other personal data.

To protect, investigate, and deter fraudulent, unauthorized, or illegal activity.

5. DISCLOSURE OF PERSONAL DATA


We may share personal information as follows:

Advertising Partners. Advertisements appearing on the Service may be delivered to users by advertising partners who may set cookies. These cookies allow the advertising server to recognize your computer each time it sends you an online advertisement in order to collect information about you or others who use your computer. This information enables the advertising networks to, among other things, serve targeted advertisements that they believe will be of greatest interest to you. This Privacy Policy covers the use of cookies by the Service and does not cover the use of cookies by advertisers, each of which has its own privacy policy.

Service Providers. We engage service providers to perform functions and provide services for us. We may share your personal information with such service providers, provided that such obligations are in accordance with this Privacy Policy and other appropriate confidentiality and security measures, and provided that the third parties only use your personal information on our behalf and in accordance with our instructions.

Payment Processors. We share your payment information with payment service providers to:

A. Process payments;

B. To prevent, detect, and investigate fraud or other prohibited activities;

C. Facilitate the resolution of disputes such as chargebacks or refunds;

D. For other purposes related to credit or debit card acceptance. We may share your credit or debit card number with payment service providers or card networks to monitor card transactions at participating merchants and to track redemption activity for the purpose of providing card-linked services.

Authorized Personnel. Our employees, agents, consultants, contractors or other authorized personnel, including employees of our contractors, service providers, subsidiaries and affiliates, may have access to user information as necessary in the normal course of business.

Business Transfers. In some cases, we may decide to buy or sell assets or engage in discussions with a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of our assets, whether as a going concern or as part of a bankruptcy, liquidation or similar proceeding, in which personal information we hold about our service users is one of the transferred assets. In this type of transaction, user data is generally one of the transferred business assets. If the service or business, or substantially all of its assets, are acquired, liquidated or dissolved, user data will be one of the transferred assets.

Authorities, Law Enforcement Agencies or Third Parties. We may, in our sole discretion and without your prior permission, disclose any information, including personal data, that we deem necessary to comply with any applicable law, regulation, legal process or governmental request. We may also share information, including personally identifiable information, with other companies and organizations to protect the rights, property or safety of the Company and its affiliates, employees, users, third parties or others. We reserve the right to disclose a user's personal information if we believe in good faith that the user is in violation of the Terms of Use, even in the absence of a subpoena, warrant or other court order.

Social Media Networks. We may embed applications or widgets from social media networks that allow interaction or sharing of content by their users. These widgets, such as a Facebook "Share" or "Like" button, are visible to you on the website you visit. The integration between the Service and social networks such as Facebook, Twitter, and others may allow the social networks you participate in to collect information about you, even if you do not explicitly enable the network's application or widget. Please visit each social network's privacy policy for a better understanding of its data collection practices and the choices available to you. The social network's privacy policy governs the collection, use, and disclosure of any personal information submitted to that network.

Push Notifications. We may occasionally send you push notifications through our mobile apps to provide you with updates and other service-related notifications that may be relevant to you. You can opt-out of receiving these types of notifications at any time by disabling them at the device level through your settings.

We may also share aggregated and/or anonymized data with others for their own purposes.

6. CHILDREN


The Service is not intended for children and is not directed to anyone under the age of 13 (or 16 if you are a resident of the European Union ("EU")). We do not knowingly collect information from anyone under the age of 13 (or 16 if you are a resident of the EU), nor do we knowingly allow anyone under the age of 13 (or 16 if you are a resident of the EU) to register for the Service. If we learn that we have collected personal information from a child under the age of 13 (or 16 if you are an EU resident) without parental consent, we will delete that information. If you believe that we may have information from or about a child under the age of 13 (or 16 if you are an EU resident), please contact us at the address below.


7. SELECTION AND CHANGE OF INFORMATION


Choice. In accordance with local law, your controls and choices may include:

A. You may correct, update and delete your account information as described below;

B. You can change your choice of subscriptions and newsletters;
C. You can choose whether or not to receive offers from us;
D. You can choose whether or not to receive targeted advertising from us or our partners.

Opt-out. If you do not want us to use your email address and other contact information to promote our own or third party products or services, you can "opt out. Our marketing emails will tell you how to opt out. If you opt out, we may continue to send you non-marketing emails. Non-marketing emails include emails about your accounts and our business relationship with you. You may also send requests for personal information to our contact information below. You may request a change in contact selection, opt out of sharing with third parties, and update your personal information.

Tracking technologies. You can usually remove or reject cookies from the service through your browser settings. Many browsers are set to accept cookies until you change your settings. If you remove or reject our cookies, this may affect the functioning of the Service for you.

Location information. You can specify in your device's privacy settings whether or not to allow the service to collect and use real-time information about your device's location. If you block the use of location information, some parts of the service may not be accessible or may not function properly.

Targeted Advertising by Company. If you do not want us to use the information we collect from you or that you provide to us to serve advertisements according to our advertisers' targeting preferences, you may opt out by notifying us at the address below. You may also adjust your advertising preferences at any time in your account profile by checking or unchecking the appropriate boxes or notifying us at the address below.

Disclosure of your information for advertising and marketing by third parties. If you do not want us to disclose your personal information to unaffiliated or unassigned third parties for advertising and marketing purposes, you may opt-out by notifying us at the address below. You may also opt out at any time by logging into the Service and adjusting your user settings in your account profile by checking or unchecking the appropriate boxes, or by opting out by sending us a message at the address below.

NAI Policies. We may also use tracking technologies to collect information about your visits over time and about third-party or other online services. The Network Advertising Initiative ("NAI") is a cooperative group of advertising providers. The NAI has developed a set of privacy principles to which its members adhere. The NAI is committed to providing consumers with clear explanations about Internet advertising practices and their impact on you and the Internet in general. For more information about the NAI, third-party ad servers in general, and the opt-out options offered by the NAI, please visit http://www.networkadvertising.org/index.asp.

Accessing and Correcting Information. If you have an account, you can help ensure that your contact information and preferences are accurate, complete and up to date by logging into your account or emailing us at the address below. You may access other personal information in our possession for any purpose, including requesting that we correct the information if it is inaccurate or delete the information if we are not required to retain it by law or for legitimate business reasons. We may decline to process requests that are frivolous/disreputable, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law.

8. DATA SECURITY

8.1. security measures


We have put in place physical, electronic, and managerial procedures to help prevent unauthorized access, maintain data security, and ensure the correct use of the information we collect online. These safeguards vary depending on the sensitivity of the information we collect and store. The protection and security of your information also depends on you. If we have given you (or if you have chosen) a password to access certain parts of the Service, you are responsible for keeping that password confidential. We ask that you do not share your password with any third party.

8.2. No security guarantees


Unfortunately, the transmission of information via the Internet and mobile platforms is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted through the Service. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide. Although we take reasonable steps to protect against unauthorized disclosure of personal information, we cannot assure you that personal information will never be disclosed, altered or destroyed in a manner inconsistent with this Privacy Policy.


9. USERS FROM OTHER JURISDICTIONS


By using the Service, you acknowledge that you accept the practices and policies set forth in this Privacy Policy and agree that your information may be transferred to and processed on computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may differ from those in your jurisdiction. If you do not accept this Privacy Policy, please do not use the Service. The Service is controlled and operated by Company from within the United States. If you are not a resident of the United States or are located outside of the United States and wish to use the Service or provide information to us, please note that we will transfer the information, including Personal Data, to and process it in the United States. By accepting this Privacy Policy and subsequently submitting such information, you consent to such transfer. We do not represent or warrant that the Service, or any part thereof, is appropriate or available for use in any particular jurisdiction. Those who access the Service do so on their own initiative and at their own risk, and are responsible for compliance with all local laws, rules and regulations. In connection with your use of the Service, you are also subject to United States export controls and are responsible for any violations of those controls, including but not limited to United States embargoes or other federal rules and regulations restricting exports. We may limit the availability of the Service, in whole or in part, to any person, geographic area or jurisdiction of our choosing, at any time and in our sole discretion.

10. FOR RESIDENTS OF THE EUROPEAN UNION ("EU") - GENERAL DATA PROTECTION REGULATION ("GDPR")


This Privacy Policy describes how EasyQuant collects, uses and shares your personal information. If you are located in the EU, you are subject to the GDPR, which takes effect on May 25, 2018, and the following provisions also apply to you. EasyQuant is the controller and responsible for your personal data. We are based in Germany, and all of your personal data is processed in Germany and the United States.


10.1 Data Privacy Officer


We have appointed a Data Protection Officer (DPO) who is responsible for overseeing issues related to this Privacy Policy. If you have any questions about this Privacy Policy, including requests to exercise your legal rights, please contact the DPO using the contact details below.


10.2 Lawful basis for the processing of your personal data


This Privacy Policy describes what personal data we collect from you and how we use it. We will only use your personal information when the law allows us to do so. In most cases, we will use your personal data in the following circumstances:

If we need to fulfil the contract that we will enter into or have entered into with you.

If it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

If we have to comply with a legal or regulatory obligation.

You have the right to withdraw your consent to marketing at any time by contacting us. Specifically, we have a lawful basis for processing each type of personal data described in this Privacy Policy, as follows:

The lawful basis for collecting your identity and contact information to register you as a new customer is to fulfill a contract with you.

The lawful basis for collecting your identity, contact, financial, transactional, marketing and communications data to process and deliver your purchases is (a) to perform a contract with you and (b) it is necessary for our legitimate interests.

The lawful bases for collecting your identity, contact, profile, marketing and communication data to manage a relationship with you are (a) the performance of a contract with you and (b) the need for our legitimate interests (to keep our records up to date and to study how customers use our products/services).

The lawful bases for collecting your Identity Data, Contact Data, Profile Data, Usage Data, and Marketing and Communications Data to enable you to participate in a contest, competition, or survey are (a) the performance of a contract with you and (b) it is necessary for our legitimate interests (to study how customers use our products and services in order to develop them and grow our business).

The lawful basis for collecting your identity, contact and technical data to administer and protect our business and the Service is that it is necessary for our legitimate interests (for running our business, providing administrative and IT services, network security, fraud prevention and as part of a corporate reorganization or group restructuring).

The lawful basis for collecting your identity, contact, profile, usage, marketing, communications and technical data in order to provide you with relevant service content and advertising and to measure or understand the effectiveness of the advertising we provide to you is that it is necessary for our legitimate interests (to study how customers use our products/services, to develop them, to grow our business and to inform our marketing strategy).

The lawful basis for collecting Technical Data and Usage Data to use data analytics to improve our service, marketing, customer relationships and experience is that it is necessary for our legitimate interests (to define customer types for our products and services, to keep our service current and relevant, to develop our business, and to inform our marketing strategy).

The lawful basis for collecting identity, contact, profile, usage and technical data to make suggestions and recommendations to you about goods or services that may be of interest to you is that it is necessary for our legitimate interests (to develop our products/services and grow our business).

We do not collect special categories of personal data about you (this includes information about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). We also do not collect information about criminal convictions and offenses.

Note that we may process your personal data for more than one lawful reason, depending on the specific purpose for which we use your data. Please contact us if you need details about the specific lawful ground on which we rely to process your personal data when more than one ground is mentioned in this Privacy Policy.

10.3 Disclosure of your personal data


We may need to share your personal information with the parties listed below for the purposes described in this Privacy Policy.

External Third Parties:

Service providers acting as processors located in the United States that provide automated marketing services.

Professional advisors acting as processors, including marketing agents, accountants, and insurers based in the United States that provide consulting and accounting services.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third party service providers to use your personal data for their own purposes and only allow them to process your personal data for specific purposes and in accordance with our instructions.


10.4 Data security


We have taken reasonable security precautions to prevent your personal information from being accidentally lost, used, or accessed, altered or disclosed in an unauthorized manner. In addition, we limit access to your personal information to those employees, agents, contractors and other third parties who need to know that information for business reasons. They will only process your personal data on our instructions and are bound to confidentiality. We have procedures in place to deal with suspected personal data breaches and will notify you and any relevant supervisory authorities of a breach where we are required to do so by law.


10.5 Data storage


We will retain your personal information only for as long as is necessary to fulfill the purposes for which we collected it, including to comply with legal, accounting or reporting requirements. To determine the appropriate retention period for personal information, we consider the amount, nature and sensitivity of the personal information, the potential risk of harm from unauthorized use or disclosure of your personal information, the purposes for which we process your personal information and whether we can achieve those purposes by other means, and applicable legal requirements. In certain circumstances, you may ask us to delete your data. In certain circumstances, we may anonymize your personal information for research or statistical purposes (so that it can no longer be associated with you), in which case we may use that information indefinitely without further notice to you.

10.6 YOUR LEGAL RIGHTS UNDER THE GDPR


In certain circumstances, EU residents have rights under data protection laws with respect to their personal data. If you are an EU resident, you have the right to:

Request access to your personal data. This will allow you to obtain a copy of the personal data we hold about you and verify that we are processing it lawfully.

Request the correction of the personal data we hold about you. This allows you to have incomplete or inaccurate data we hold about you corrected, and we may need to verify the accuracy of the new data you provide to us.

You can request the deletion of your personal data. This allows you to request that we delete or remove your personal data if there is no valid reason to continue processing it. You also have the right to ask us to erase or remove your personal data if you have successfully exercised your right to object to processing (see below), if we may have unlawfully processed your data, or if we are required to erase your personal data to comply with local laws. However, please note that we may not always be able to comply with your request for erasure for certain legal reasons, which may be communicated to you at the time of your request.

You may object to the processing of your personal data if we rely on a legitimate interest (or that of a third party) and there is something in your particular situation that causes you to object to the processing on that ground because you consider that it affects your fundamental rights and freedoms. You also have the right to object when we process your personal data for direct marketing purposes. In some cases, we may be able to demonstrate that we have compelling legitimate grounds for processing your data that override your rights and freedoms.

You may request the restriction of the processing of your personal data. This allows you to ask us to suspend the processing of your personal data in the following cases: (a) if you want us to verify the accuracy of the data; (b) if our use of the data is unlawful but you do not want us to delete it; (c) if we need to keep the data even if we no longer need it because you need it to establish, exercise or defend legal claims; or (d) if you have objected to our use of your data but we need to verify that we have compelling legitimate grounds for using it.

Request the transfer of your personal data to you or to a third party. We will provide you or a third party selected by you with your personal data in a structured, commonly used and machine-readable format. Note that this right only applies to automated data that you have originally consented to the use of, or if we have used the data to perform a contract with you.

You can revoke consent at any time when we invoke consent to process your personal data. However, this does not affect the lawfulness of the processing that took place before you withdrew your consent. If you withdraw your consent, we may no longer be able to offer you certain products or services. We will inform you if this is the case when you revoke your consent.

If you wish to exercise any of the above rights, please contact us. You do not have to pay a fee to access your personal information (or exercise any other rights). However, we may charge a reasonable fee if your request is manifestly unfounded, repetitive or excessive. Alternatively, we may refuse to respond to your request in these circumstances. We may need to request certain information from you to confirm your identity and to ensure your right to access your personal information (or to exercise your other rights). This is a security measure to ensure that personal information is not disclosed to anyone who does not have a right to receive it. We may also contact you to ask for more information about your request in order to expedite our response. We aim to respond to all legitimate requests within one month. Occasionally, it may take longer than one month if your request is particularly complex or you have made multiple requests. In this case, we will notify you and keep you informed.


11. CONTACT INFORMATION

We welcome your comments or questions about this privacy policy. You can also contact us at:

EasyQuant

info@easyquant.io