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Privacy Policy

GENERAL

Financial Samurai Ltd. (“Samurai”) provides a variety of financial tools and information to individual investors, including, without limitations, powerful options trading tools and strategies (the “Services”). Samurai is committed to protecting the confidentiality and security of information we collect about our end-users (“you”).

BY USING OUR SERVICES, YOU ACKNOWLEDGE AND AGREE THAT WE WILL COLLECT, USE AND TRANSFER YOUR PERSONAL DATA FOR PROCESSING AS DESCRIBED IN THIS PRIVACY POLICY.

This Privacy Policy aims to give you information on how Samurai collects and processes your Personal Data through your use of our websites or mobile applications or through our software platform, including any data you may provide when you apply for an account or subscription or use a Service. This Privacy Policy describes the types of Personal Data we may gather and the circumstances under which we may share it. Samurai respects your privacy and is committed to protecting your Personal Data. This Privacy Policy will inform you of how we use your Personal Data and tell you about your privacy rights and how the law protects you.

In order for Samurai, as a Controller, to comply with the requirements of the European Union (“EU”) General Data Protection Regulation (“GDPR”) for our EU end-users, this Privacy Policy outlines the legal basis on which we process your Personal Data and provides other information required by the GDPR.

DATA WE COLLECT

For purposes of this Privacy Policy, Personal Data means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. Personal Data does not include data that has been anonymized in accordance with applicable law (anonymous data). Please note that the above definitions are in compliance with the requirements of the GDPR.

We may collect, use, store and transfer the following types of Personal Data about you:

  1. Identity Data: may include your name, username or similar identifier, date of birth, and other identity details you choose to provide to us.
  2. Contact Data: may include mailing address, email address and telephone numbers.
  3. Financial Data: may include information about your investments, portfolio size, trading activity, investment experience, and other financial profile information you choose to provide (such as income or net worth). Providing this information is voluntary; however, some features may be limited without it. Payment card details are processed by our third-party payment processor and are not stored on our servers.
  4. Transaction Data: may include details about payments to and from you, transactions made by you and other details of Services you have purchased from us.
  5. Technical Data: may include internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services.
  6. Usage Data: may include information about how you use our websites, mobile applications, products and services.
  7. Geo-location Data: may include information about your geographic location based on internet protocol address.
  8. Marketing and Communications Data: may include your preferences in receiving marketing from us and third parties and your communication preferences.
  9. Connected Account Data: if you choose to connect a brokerage or other third-party account to our Services, we may receive information from that account, such as account identifiers, positions, balances, orders and transaction history, and we may send information to that account at your instruction, such as trade orders. Connecting an account is voluntary; however, some features may be limited without it. We do not receive or store your brokerage login password.

We also collect, use and share Aggregated Data such as statistical or demographic data for business purposes that does not and cannot be used to identify you.

Personal Data of Minors

Our Services are not intended for individuals under the age of 18 and we do not knowingly collect data relating to children.

HOW PERSONAL DATA IS COLLECTED

We obtain most Personal Data directly from you, when you apply for, access and use the Services. We use different methods to collect data from and about you, including through, direct instructions, automatic means or through third parties.

WHY WE COLLECT AND USE PERSONAL DATA

We may use your Personal Data under the following circumstances: (i) Where we need to perform under the contract we are about to enter into or have entered into with you or where we seek to deliver and improve our Service to you; (ii) Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests, all in accordance with applicable laws; (iii) Where we need to comply with a legal or regulatory obligation; or (iv) Where you have given your consent to collection and/or processing.

Examples of purposes for which we may use your Personal Data include: To onboard you as a new customer, to process your orders and transactions, to send and receive payments, to keep in touch with you, to send you commercial offers from us or from our partners, to make sure the activity is performed in accordance with our policies and with all applicable laws and regulations, to improve, maintain and provide support to the Services, to personalize your experience and the content and features we offer you, to better understand our users and audience for business and marketing purposes, and for analytic purposes.

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If we need to use your Personal Data for an unrelated, new, or additional purpose, we will notify you, explain the legal basis which allows us to do so and obtain your consent to use the Personal Data for the unrelated, new, or additional purpose.

Opting out from receiving commercial offers (marketing communications)

You can ask us to stop sending you marketing materials at any time by contacting us at: [email protected] for assistance and further instructions or by unsubscribing via the links provided in marketing emails.

Cookies

Cookies are blocks of textual information that are sent electronically from a web server to your browser and are stored on your computer or mobile device. We may use cookies to facilitate the use of analytics tools that measure and identify traffic patterns and to track the performance of features and advertisements. By increasing our understanding of how you and our other customers and visitors use our services, cookies enable us to continually improve the form and functionality of our services and to convey to you the most relevant information and current offers. Information gathered through the placement and tracking of cookies may be shared with Samurai employees, agents and affiliates, but we do not sell such information to unaffiliated third parties.

Samurai may allow other companies or third-party advertising services to place cookies onto your computer or mobile device while browsing our website or, if applicable at any time, our mobile application. In such cases, these third-party companies generally use these cookies in a manner consistent with our use and are typically doing so in support of campaigns sponsored by Samurai.

You may optionally refuse or delete cookies. Most web browsers and mobile devices offer settings that permit the user to manage cookies. You can set your browser or mobile device to refuse all or some browser cookies, or to alert you when websites or mobile applications set or access cookies. Please note that if you should elect to refuse or delete cookies provided by our website or Services, you may experience some inconvenience in your use of our Services. For example, you may be asked for additional verification while signing in to access your account, or we may not be able to recognize your device or your previously established online preferences.

DISCLOSURES OF PERSONAL DATA TO THIRD PARTIES

We do not sell your Personal Data to third parties. Additionally, we do not disclose Personal Data about our users to third parties, except as described below or as required or permitted by law. We may disclose Personal Data when we believe it necessary for the conduct of our business. Personal Data may be disclosed for audit or research purposes to attorneys or other professionals, or to law enforcement and regulatory and self-regulatory agencies to help us prevent fraud. We may also disclose Personal Data in connection with a proposed or actual corporate transaction, including a reorganization or sale of some or all of Samurai’s assets or securities. In addition, we may disclose Personal Data to marketing affiliates, and affiliated and non-affiliated third-party service providers. We will require all third parties that receive any Personal Data to agree in writing to confidentiality and non-disclosure obligations.

INTERNATIONAL TRANSFERS

If you are located outside of the United States, please be aware that Personal Data we collect will be processed and stored in the United States. By using our Services and submitting your Personal Data, you acknowledge that we will transfer, store and process your Personal Data in the United States. In addition, third-party service providers that process your Personal Data on our behalf (as described above) may be based outside the EU or may use cloud service providers to process and store your Personal Data outside the EU.

Note to Residents of the European Union: Whenever we transfer your Personal Data out of the EU, we ensure your Personal Data is protected in accordance with GDPR requirements by ensuring at least one of the following safeguards is implemented: (i) We will only transfer your Personal Data to countries (or using mechanisms) that have been deemed to provide an adequate level of protection for Personal Data by the European Commission; (ii) Where we use certain third-party service providers, we may use specific contracts approved by the European Commission which give Personal Data the same protection it has in the EU; or (iii) Where we use certain third-party service providers based in the U.S., we may transfer data to them if they are certified under the EU-U.S. Data Privacy Framework, or pursuant to the above approved contracts.

DATA SECURITY

We have put in place physical, administrative and technical security measures designed to protect the confidentiality, integrity, availability and resilience of Personal Data, and designed to prevent the accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to, Personal Data transmitted, stored or otherwise processed. In addition, we limit access to your Personal Data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal Data on our instructions and they are subject to a duty of confidentiality.

We use industry standard security technologies and procedures to help protect your Personal Data from unauthorized access, use or disclosure. Samurai uses secure servers with strong password protection. Industry standard Transport Layer Security (TLS) and HTTPS protocols are used to protect your Personal Data. We also use firewalls and other security technology to help protect our network and systems from external attack and take industry standard steps to back up and protect your Personal Data.

DATA RETENTION

We will only retain your Personal Data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements.

To determine the appropriate retention period for Personal Data, we consider the amount or quantity, nature and sensitivity of the Personal Data, the potential risk of harm from unauthorized use or disclosure of your Personal Data, the purposes for which we process your Personal Data, and whether we can achieve those purposes through other means, and the applicable legal requirements.

Note to Residents of the European Union and California: In some circumstances you can ask us to delete your data. California Residents and European Union Residents have additional rights.

EUROPEAN UNION RESIDENTS

Samurai takes measures to keep your Personal Data accurate and up to date. If you reside in the EU or are a citizen of the EU, under certain circumstances, you have rights under data protection laws in relation to your Personal Data. To exercise your rights to your Personal Data, please contact us at: [email protected]. You have the following rights: (i) the right to request access to your Personal Data; (ii) the right to request correction of your Personal Data; (iii) the right to request erasure of your Personal Data; (iv) the right to request restriction of processing of your Personal Data; (v) the right to data portability or request the transfer of your Personal Data to you or to a third party; (vi) the right to withdraw consent at any time where we are relying on consent to process your Personal Data; and (vii) the right to object to processing of your Personal Data where we rely on our legitimate interests, including the right to object at any time to processing for direct marketing purposes.

If you believe that our processing of your Personal Data infringes applicable data protection laws, you also have the right to lodge a complaint with the data protection supervisory authority in the EU member state where you reside or work.

Residents of California - Your Privacy Rights:

California Civil Code Section 1798.83 permits California residents to request and obtain from us a list of what Personal Data (if any) we disclosed to third parties for that third party’s direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, if we were to share your Personal Data with third parties for their marketing purposes, you may opt-out of this disclosure at any time by submitting a request to us in writing at: [email protected]

Please note that this opt-out option does not extend to disclosures made for non-marketing purposes or our own marketing purposes. It is only limited to the third party’s direct marketing purposes. Making requests for removal does not ensure complete and/or comprehensive removal of your Personal Data. Personal Data may be retained pursuant to our internal recordkeeping requirements and/or applicable law.

On June 28, 2018, California enacted the California Consumer Privacy Act of 2018 (CCPA), which has an effective date of January 1, 2020. The CCPA provides California residents with specific rights regarding their Personal Data, which are described below. If you reside in California, you can exercise these rights by contacting us at: [email protected]

  1. Right to receive notice before or at the point of collection, about what Personal Data categories we collect and its intended purpose.
  2. Right to know and access categories of Personal Data and the specific types of Personal Information collected, the categories of sources from which Personal Data is collected, the business or commercial purpose for collecting and/or disclosing the Personal Data, the categories of third parties who have access to your Personal Data.
  3. Right to request deletion of your Personal Data, subject to certain exceptions.
  4. Right to opt-out of the sale of your personal data if you are 16 years of age or older.
  5. Right to not face discrimination for asserting your rights subject to certain parameters.