Privacy Policy

In brief: We are CMC GLOBAL MARKETS Inc. ("CMC GLOBAL MARKETS" or "we" or "us"). We respect your privacy and the confidentiality of information that you give us. We will share your personal data with third parties only in the event that it’s needed for the provision of services and data you have requested (which is explained in detail in this privacy policy).

About Us
CMC GLOBAL MARKETS is the data controller responsible for your personal data and is the sole owner of cmcgm.org website ("Website") and all of the information collected on it. CMCGLOBAL collects information from users in several ways through the Website (which is explained in detail in this privacy policy).
This privacy policy applies to personal data that we collect from you when you visit this Website or create an account ("you" or "your" being interpreted accordingly). It provides information on what personal data we collect, why we collect the personal data, how it is used, the lawful basis on which your personal data is processed, how it is stored, and how we share information.
As used in this privacy policy, "personal data" means any information that relates to you from which you can be identified.
By using our Website or submitting your personal data, you are taken to accept the terms of this privacy policy, so please read it carefully.

Updates
We may update this privacy policy at our discretion from time to time by posting a new version on our Website. You should check our Website occasionally to ensure any changes made are suitable for you. If required by applicable law, you will be informed of any significant changes made to the privacy policy.
Current version of this privacy policy was modified on May 1, 2019.

Personal data that we collect
There is no need to create an account when searching and viewing information from certain markets on the Website, such as symbols, quotes, financial data as well as ideas and publicly available data of CMC GLOBAL MARKETS users.

Data we receive from you
User Accounts
If you decided to create an account you will need to provide some personal data to us so that we can provide you with access to our additional services that account users benefit from. You may also elect to provide us with additional information about you, as described below.
During registration you will be required to provide us with either:
your username, email address; your account information with one of the following social Internet services: Facebook, Twitter, Google, Yahoo!, LinkedIn; and if you want to buy a subscription, your first name, last name and postal address
. In some cases you may need to provide and verify your phone number. You can also add additional information about yourself in the profile settings, however this is not mandatory:
the following information will be publicly displayed - the image you have elected to provide as your user avatar, signature, “about me”, location, Twitter handle and website; and the following information would not be publicly available - first and last name, phone, email, company, address and taxpayer ID.
If you register to be a user of PRO/PRO Plus/Premium Accounts (a "Paid User"), our third party payment processor (PayPal) will also process information about your debit/credit card and bank account information, that we require for the purpose of recording and processing your account registration. For further details please also refer to the point below headed "Payment information" under the section headed "When we share your personal information".

Contact data
We also process any personal data you choose to give when corresponding with us by phone or e-mail or otherwise visiting and interacting with this Website or any other websites we operate.

Cookies and other technologies
We use cookies (small text files placed on your device) to administer our Site, gather and analyze statistical information, ensure security and to fight spam and for advertising purposes. Cookies allow us to provide you with a better user experience when you browse our Website and to improve its features. More detailed information on the use of cookies can be found in our Cookies Policy.
We also use web beacons (tiny graphics with a unique identifier) for analytics and advertising purposes and to develop, test and improve our services further, as described in our Cookies Policy.
Log files
Like most websites, we use web server log files. Records in our log files include internet protocol (IP) addresses (see "Device information" section below for further details), browser types, internet service providers, referring pages, exit pages, platform types, and date/time stamps. We use web server log files to administer the site, to provide broad traffic information for site planning purposes, and to ensure that our terms of service agreement are being adhered to. IP addresses are not tied to personal data in our web server log files.

Device information
We collect the following information about the devices that you use to visit the site: IP address of the device (from which we can also infer the country you are connecting from at the time you visit the Website), operating system and browser version. We are collecting this information to prevent spam and abuse of our services. IP addresses may be considered personal data in certain jurisdictions, such as in the European Economic Area ("EEA"), and will be treated in accordance with this privacy policy.
When you are using our mobile application, we may collect your general device information, device identifier (for example, Google Advertising ID, if you are using an Android device, or Advertising Identifier (IDFA), if you are using an iOS device), network information and application interaction events for analytics purposes and to develop, test and improve our services further. Our mobile applications use third party services that may collect such information. For further details please also refer to the Analytics providers section below.

Data we receive from third parties
When you sign in to the Website or service using your social internet service credentials (Facebook, Twitter, Google, Yahoo!, LinkedIn, StockTwits), such service sends us your username and email address associated with the credentials you've used. We neither control nor take any responsibility for the way third parties that provide information about you process your personal data.

How personal information is used
We use your personal data in various ways that are necessary to provide the services you have asked us to provide, for certain legitimate interests and as necessary to comply with applicable law, as further described below.
We do not generally rely on your consent to allow us to process your personal data if there is another lawful ground available. If we do rely on your consent we will make this clear to you at the time.

Profile
A profile is a set of information for each individual user that details his/her viewing preferences. We do not use stored user settings for marketing purposes. User settings (chart settings, toolbars, buttons, etc.) are kept solely for the purpose of customizing user experience when using Website or user accounts. We do not share your private profile settings with any third parties.
When you create an account on the Website, other users or visitors to the Website may access your public profile on our Website and see any information you have made publically available about yourself.

User account and profile operations
*We use your contact details, such as username, email address or phone number, in the following ways: *
to authenticate your user account, ensure its security along with the security of our services and to prevent spam, fraud and abuse; to acknowledge, confirm and deal with your user account; to send all new users a welcome activation email to verify their email address; where you are a Paid User, to provide you with subscription services and contact you regarding your use of the services. Such use is necessary to respond to or implement your request and for the performance of the contract between you and us; and Paid Users will also receive a notification email from PayPal if there are any issues with billing their cards for auto-renew subscriptions. Users cannot opt-out of these messages, though they can deactivate their account.

Marketing
We may send you marketing emails about products or services of ours which are similar to the products or services you subscribed to, including information about events and other promotions we feel may interest you, unless you have indicated to us that you do not wish to receive communications in this manner. We will send you by email other promotional information only with your consent, which was given at the time you provided us with the personal data. Users can opt-out of receiving marketing communications at any time by clicking unsubscribe in one of the emails (for more information on your rights, please see "User rights" section below).

Social Notifications
We can notify you via email about new users who have followed you/liked an idea and/or about new ideas of users that you follow etc. You can refuse to receive such notifications at any time by adjusting your user settings.

Service-Related Announcements
On rare occasions it is necessary to send out service-related announcements. For instance, if our service is interrupted for a prolonged period or major functionality upgrade is released, we might send all users an email message.

Customer Service
When you open a support ticket we use your contact details as well as information about your device, server logs, a description of the problem along with any supporting materials (videos, screenshots) to help you resolve the issues.

API
If you are using our API (application programming interface) services (such as the Charting Library, Trading Terminal, REST API) then we can process your personal data in order to be able to provide and support those services.

Legitimate interests
We will process your personal data as necessary for certain legitimate business interests, which include the following:
where we are asked to deal with any enquiries or complaints you make; to administer our Website, to better understand how visitors interact with the Website and ensure that our Website is presented in the most effective manner for you and for your computer/device;
to develop and improve our mobile applications;
to share personal data among our affiliated businesses for administrative purposes, for providing subscription services and in relation to our sales and marketing activities (except where we require your consent, as described above);
to send you information about products or services of ours which are similar to the products or services you subscribed to (unless you have refused or opted out of receiving these emails at the time you provided us with your email address or you have later indicated to us that you do not wish to receive communications in this manner). Our legitimate interest is to ensure our marketing is relevant to you, so we may process your data to send you information on our products or services that is tailored to your interests; we may anonymise, aggregate and de-identify the data that we collect and use such anonymised, aggregated and de-identified data for our own internal business purposes, including sharing it with our business partners, our affiliated businesses, agents and other third parties for commercial, statistical and market research purposes, for example to allow those parties to analyse patterns among groups of people, and conducting research on demographics, interests and behavior;
for internal business/technical operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our Website, network and information systems secure; and to (a) comply with legal obligations, (b) respond to requests from competent authorities; (c) enforce our Terms of Use or House Rules; (d) protect our operations or those of any of our affiliated businesses; (e) protect our rights, safety or property, and/or that of our affiliated businesses, you or others; and (f) enforcing or defending legal rights, or preventing damage. This means we can store and disclose your information to law enforcement authorities, state or government agencies if we establish that such disclosure is necessary to comply with the law. This includes responses to court orders or subpoenas, as well as other judicial or regulatory processes.
As used in this privacy policy, “legitimate interests” means the interests of CMC GLOBAL MARKETS and our affiliated businesses in conducting and managing our business. When we process your personal data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests. We will not use your personal data for activities where our interests are overridden by the impact on you, unless we have your consent or those activities are otherwise required or permitted to by law. You have the right to object at any time to processing of your personal data that is based on our legitimate interests, on grounds relating to your particular situation (for more information on your rights, please see "User rights" section below).

When we share your personal information
We share your personal data with third parties in the following situations:
Service providers: CMC GLOBAL MARKETS , like many businesses, occasionally engages selected third parties who act on our behalf to support our operations, such as (i) card processing or payment services (see the point below headed "Payment information"), (ii) IT suppliers and contractors (e.g. data hosting providers or delivery partners) as necessary to provide IT support and enable us to provide subscription services and other goods/services available on this Website or to users, (iii) web and mobile analytics providers, (iv) providers of digital advertising services and (v) providers of marketing and sales software solutions. Pursuant to our instructions, these parties may access, process or store your personal data in the course of performing their duties to us and solely in order to perform the services we have hired them to provide.
Payment information: Paid Users must provide payment information (name, credit card information or PayPal account information). This information is used for billing purposes only and is processed by PayPal, that is our payment processor. When you are making a payment, we do not have access to your personal and credit card information. Should we have any issues with processing an order, the email address provided will be used to contact you. Third Party Content Providers: When you buy market data from IDC we give them your contact details, phone number, address, email and you sign the agreement. This data is also processed by IDC in order to provide you with access to the exchanges. When you buy market data from another stock exchange we give them same information.
CMC GLOBAL MARKETS affiliated businesses: In order to provide the services you request from us, our affiliated businesses may access and process the information which we collect from you for the purposes described above, including offering products and services to you. Our affiliated businesses will only use your data for the purposes for which we originally collected it.
Analytics providers: We may use third-party service providers to monitor and analyze the use of our services and mobile applications. We use this information to analyze and improve the work of our services and mobile applications.
We may use Google Analytics as a web analytics service. For more information on Google Analytics privacy practices, please go here.
Analytics services for mobile applications that we may use:
Firebase is a development and analytics platform provided by Google. For more information on what type of information are collected, please visit the Google Privacy web page.
Flurry Analytics provide us tools and resources for understanding our mobile application users’ behavior. For more information on the handling of user data on Flurry App Analytics, please see Privacy Policy.
Amplitude is an analytics service for mobile apps. For more information on the privacy practices of Amplitude, please see the Amplitude Terms. Visual Studio App Center is owned by Microsoft and their applicable data protection provisions may be reviewed under Microsoft Privacy Statement. Business transfers: If we sell our business or our company assets are acquired by a third party personal data held by us about our general account users, subscription account users or customers may be one of the transferred assets.
Administrative and legal reasons: if we need to disclose your personal data (i) to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process. (ii) to enforce our Terms of Use, House Rules or other applicable contract terms that you are subject to or (iii) to protect us or our contractors against loss or damage. This may include (without limit) exchanging information with the police, courts or law enforcement organisations.

Advertising
We display advertising on the Website and use remarketing and tracking features provided by Google, Facebook and Twitter. Remarketing feature allows to display advertising in a more targeted manner in order to present advertisements of interest to users, based on activity on other websites. Tracking features allow us to collect information about impressions, ad clicks and certain actions that you complete through our website. This data also helps us evaluate the performance of ad campaigns. Note that we collect pseudonymous data only.
For more information about Google’s use of data for marketing purposes, please see https://www.google.com/policies/technologies/ads and Google’s Privacy Policy.You can opt out from remarketing and/or targeting by visiting the Network Advertising Initiative opt-out page or turning off personalization of Google ads, on the Ad Settings page.

Note that you can learn more about Facebook’s data policy here. You can manage your personal settings for advertisements on Facebook at https://www.facebook.com/ads/settings. For more information about Twitter data processing please see their Privacy policy. You can adjust the settings in your personal Twitter profile and opt in to receive advertising. In case you don’t have a Facebook and/or a Twitter account, you can use http://www.youronlinechoices.com/ or http://optout.aboutads.info/ to manage your ad experience.

Note that we don’t share any personal information with our advertisers. They can only access general statistics that include the amount of impressions their ads have generated as well as clicks.

Public information on our site

Public Profile
When you create your profile on Website, other users or visitors may access your public profile on our Website and see any information you have made available about yourself. When browsing the Website for trading ideas they will only be able to view your: market information (published ideas and scripts, markets allocation, top mentioned Symbols), social information (followers and following lists along with the ideas that you follow and comment on), contact information ("About me" section, location, Twitter, website), your community status (Moderator or PRO badges, statistical information such as reputation points, views, likes, followers, registration date as well last visit date). Your email address will not be visible (until you choose to make it visible).

Public Charts, Ideas and Scripts

Our Website allows those with a user account to share their charts with indicators and comments added ("ideas") and scripts with the rest of the internet via our publish idea and scripts feature. By using the publish idea and script feature, you grant us an irrevocable, perpetual, royalty-free licence to publish and disclose the content of this idea and your scripts as well as the name of the author, which makes you identifiable.
You can also publish a private idea. It will not be displayed in your profile, list of ideas and will not get indexed by search engines. However, users who have a direct link to your idea will be able to view it.

Chats and Private Messages
When you communicate with other users in public and private chats we store and process your messages and any related information. We check links to make sure that there is no malicious content as well as to detect spam and prohibited images. When you use private messages to communicate keep in mind that the recipients have a copy of your correspondence as well. This will be the case even if you delete such correspondence from your account. Recipients can copy, store or reshare these messages.

Security of personal data
We use technical and organizational safeguards to protect your personal data and require third parties with whom we work to do the same.
We use Transport Layer Security (TLS) encryption technology in order to protect certain information that you submit. This type of technology protects you from having your information intercepted by anyone while it is being transmitted to CMC GLOBAL MARKETS or PayPal. While on a secure page, such as our order form, the "lock" icon in the browser window is displayed, confirming that a secure, encrypted connection has been established with the Website. We work hard to ensure that our Website is secure and that we meet industry standards. We also use other safeguards, such as firewalls, authentication systems (e.g., passwords and personal identification numbers), and access control mechanisms to control unauthorized access to systems and data. Where you have chosen to create an account, you are responsible for doing everything you reasonably can to keep your access details secret. You must not share these details with anyone else.
We also do our best to protect user information offline. All of our users' personal information is restricted to our offices. Only employees who need to see the information to perform their jobs are allowed to access it.
The servers that store personal data are located in a secure environment in a locked facility.
We are constantly improving the ways we secure the data we collect, store and process, including physical security measures that help us counter unauthorized access to our systems. However, no method of electronic transmission or storage is 100% secure. Therefore, we cannot guarantee its absolute security.

Children’s and sensitive personal data

This Website is not directed to children who are under the age of 18. We do not knowingly contact or collect personal information from children below the age of 18 years or sensitive personal data (racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, biometric data, data concerning health, data concerning a natural person’s sex life or sexual orientation). If you believe we have inadvertently collected such information, please contact us so that we can either obtain special consent or delete the information.

Third Party Sites
Links to other sites
At our discretion we can add links (web links) to other websites from our Website. These websites can be run by third parties with separate and independent privacy policies. We, therefore, have no responsibility or liability for the content, activities or privacy policies of those linked sites. We suggest you read the privacy policy of each and every site that you visit.

Our hosted charting solutions
Some business partners use our charting solutions on their own websites. Such sites may display messages like "Powered by CMCGLOBAL " or similar. We do not control the privacy policies of those sites, regardless of whether such display messages are present. We suggest you read the privacy policy of each and every site that you visit.

User rights
Individuals subject to the European data protection laws may have data subject rights in relation to personal data we hold about them (described in detail below), which may be subject to limitations and/or restrictions.
If you are located in the EEA, please contact us to exercise your rights.
Accessing data
If you ask us, we will confirm whether we are processing your personal data and, if so, provide you with a copy of that personal data along with certain other details. If you require additional copies, we may need to charge a reasonable fee.

Restricting processing
You may ask us to restrict or ‘block’ the processing of your personal data in certain circumstances, such as where you contest the accuracy of the data or object to us processing it. We will tell you before we lift any restriction on processing. If we shared your personal data with others, we will tell them about the restriction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.

Objection
You may:
ask us at any time to stop processing your personal data, and we will do so, if we are relying on a legitimate interest to process your personal data - unless we demonstrate compelling legitimate grounds for the processing; object at any time to our processing of your data for the purposes of direct marketing. This can be done by clicking the unsubscribe button in marketing emails; and
refuse to receive service notifications via email (for example, when a user that you are subscribed to publishes a chart, etc.). This can be adjusted in the user settings.

Withdrawal of consent
If we rely on your consent to process your personal data, you have the right to withdraw that consent at any time. This will not affect the lawfulness of processing of your data before we received notice that you wished to withdraw your consent. We would emphasise that we do not generally rely on your consent to allow us to process your personal data if there is another lawful ground available. If we do rely on your consent we will make this clear to you at the time.

Viewing and correcting data
You have the right to have inaccurate personal data rectified, or completed if it is incomplete. In order to do so, each user can view and manage or update his/her personal data in the profile settings.
If we shared your personal data with others, we will tell them about the correction where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data so you can contact them directly.

Deleting data
You have the right to refuse to use our Website and may ask us to delete or remove your personal data in certain circumstances, such as where we rely on your consent to process your personal data and you withdraw that consent, or you object to us processing your personal data based on our legitimate interests and there is no overriding legitimate grounds for that processing. If we shared your data with others, we will tell them about the erasure where possible. If you ask us, and where possible and lawful to do so, we will also tell you with whom we shared your personal data with so you can contact them directly.
Please note that the above right of deletion is in addition to your rights to delete your user account in accordance with our Terms of Use. If you requested your account be deleted, we will delete personal data you have supplied to us, however certain personal data will be retained if it has been integrated into our systems and platform, including data in communications you have sent via our platform. This data is necessarily retained for the integrity of the platform data and legitimate business purposes, including auditing, security and other legitimate interests.
Note that search engines as well as third parties can keep copies of your publicly available information for some time once your account has been deactivated. It should also be noted that published ideas will remain on the site and messages sent to other users can’t be deleted.

Data retention
We will keep your personal data (1) until your user account is deleted by you (if requested), or by us, or (2) as required by law or as necessary for legitimate business purposes (e.g. for tax, legal, accounting, fraud or abuse prevention or other purposes), whichever is the longer.
Upon expiry of the applicable retention period we will securely destroy your personal data in accordance with applicable laws and regulations. In some circumstances we may anonymise your personal data so that it can no longer be associated with you, in which case it is no longer personal data.
When you consent to receive marketing communications, we will keep your data until you unsubscribe.

Data portability
You have the right to obtain your personal data from us that you consent to give us or that was provided to us as necessary in connection with our contract with you. We will give you your personal data in a structured, commonly used and machine-readable format. You may reuse it elsewhere.

Lodge a complaint with the data protection authority
If you have a concern about our privacy practices, including the way we handled your personal data, you can report it to any competent data protection authority of an European Union member state that is authorised to hear those concerns (you may find European Union Data Protection Authorities’ contact information here). If you wish to exercise any of these rights please contact us. We may also need to ask you for further information to verify your identity before we can respond to any request.

European Union residents: International data transfers
CMC GLOBAL MARKETS Inc. is based in the United States and has affiliates in Russia. The information collected through the Website will be stored on servers located in the United States, European Union and other destinations (including outside the EEA), to our service providers and affiliated businesses for the purposes described above. This is necessary to enable you to navigate and use our Website, and the data may be transmitted to our service providers and affiliates supporting our business operations (described above).

Please note that the countries concerned may not provide the same legal standards for protection of your personal data that you have in the EEA. Where we transfer your personal data to countries outside of the EEA we will take steps to ensure that your information receives an adequate level of security protection where it is processed and your rights continue to be protected. Some of our service providers (such as Amazon Web Services, Inc.) are certified to the Privacy Shield, a framework operated by the U.S. Department of Commerce that permits to transfer personal data outside the EEA or, as applicable, Switzerland, to certified companies in accordance with EEA data protection law (for more information visit: https://www.privacyshield.gov).

If you would like to receive more information on the safeguards that we implement, please contact us.

Contact information
If you have any questions or suggestions regarding personal data processing, please contact us at privacy@cmcgm.org.
If you are an individual in the EEA, you can also contact Jasper Ernst at C/ Aragón 643 (Mail Boxes), PO Box 194, 08026 Barcelona, Spain, who has been appointed CMC GLOBAL MARKETS's representative in the EEA pursuant to Article 27 of the European Union General Data Protection Regulation on matters related to the processing of personal data that take place in the EEA.
If you disagree with this privacy policy, you will need to stop using our Website and deactivate any user accounts.

cmcgm.org, Inc. 470 Olde Worthington Rd., Suite 200 Westerville, OH 43082