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Privacy PolicySmarttrading2024-01-22T06:55:52+00:00


PRIVACY POLICY



Effective Date: January 1, 2020

To review material modifications and their effective dates scroll to the bottom
of the page.

The Spyrol Group LLC owns and operates this smarttrading.com website business.
All references to “we”, “us”, this “website” or this “site” shall be construed
to mean The Spyrol Group LLC.

HOW WE MODIFY THIS PRIVACY POLICY

We reserve the right to modify this Privacy Policy at any time, and without
prior notice, by posting an amended Privacy Policy that is always accessible by
clicking on the “Privacy Policy” link on this site’s home page. Your continued
use of this site indicates your acceptance of the amended Privacy Policy.

Regarding Personal Information (defined below), if any modifications are
materially less restrictive on our use or disclosure of the Personal Information
previously disclosed by you, we will obtain your consent before implementing
such revisions with respect to such information.

THE TYPES OF INFORMATION WE COLLECT

Personal Information. “Personal Information” includes any information regarding
a natural person that may be used directly to identify the person. Personal
Information that we collect may vary with each separate purpose for which you
provide it, and it may include one or more of the following categories: name,
physical address, email address, phone number, credit card information including
credit card number, expiration date, and billing address, and location data.

Usage Data. We reserve the right to collect information based on your usage of
this site which is information collected automatically from this site (or third
party services employed in this site ), which can include: the IP addresses or
domain names of the computers utilized by the users who use this site, the URI
addresses (Uniform Resource Identifier), the time of the request, the method
utilized to submit the request to the server, the size of the file received in
response, the numerical code indicating the status of the server’s answer
(successful outcome, error, etc.), the country of origin, the features of the
browser and the operating system utilized by the user, the various time details
per visit (e.g., the time spent on each page within the site) and the details
about the path followed within the site with special reference to the sequence
of pages visited, other parameters about the device operating system and/or the
user’s IT environment, and data, conversion rates, marketing and conversion data
and statistics, reports, analytics data, reviews and surveys (“Usage Data”).
Usage Data is essentially anonymous when collected, but could be used indirectly
to identify a person.

HOW AND WHEN WE COLLECT INFORMATION

Personal Information. We collect Personal Information at the time you provide it
to us. We collect Personal Information through sign-up forms and as part of your
registration for an account, product, or service, promotion, or contest from
this website. Personal Information that we collect may vary with each sign-up or
registration. In addition, we collect personal information from all
communications with site visitors including without limitation, text messages,
faxes, telephone calls, and regular “snail mail”, as well as from third-party
outside sources including database vendors.

Your Communications With Us. We collect Personal Information that we receive
from you as you communicate with us. If you complete a signup form subscribing
to information from our site or to participate in our mailing list activities,
we will receive your Personal Information from our email services and/or
autoresponder service.

Usage Data. We reserve the right to monitor your use of this site. As you
navigate through this site, Usage Data may be passively collected (that is,
gathered without your actively providing the information) using various
analytics and reporting technologies, such as cookies and web beacons.

HOW WE USE YOUR INFORMATION

We may use your Personal Information for the performance of the services or
transaction for which it was given, and in connection with other products,
services, promotions, or contests we may offer, and our private, internal
reporting for this site, and security assessments for this site.

We reserve the right to make full use of Usage Data. For example, we may use
Usage Data to provide better service to site visitors, customize the site based
on your preferences, compile and analyze statistics and trends about the use of
this site, and otherwise administer and improve this site for your use. Specific
uses are described below.

INFORMATION SHARING AND DISCLOSURE

General Disclosure Policy. We reserve the right to disclose your Personal
Information as described below. We reserve the right to disclose Usage Data
without restriction.

Affiliated Entities. We reserve the right to provide your Personal Information
and Usage Data to any affiliated entities we may have, including our
subsidiaries. Affiliated entities are entities that we legally control (by
voting rights) or that control us.

Service Providers. We reserve the right to provide access to your Personal
Information and Usage Data to our trusted service providers that assist us with
the operation and maintenance of this site. For example, we may contract with
third parties to process payments, host our servers, provide security, and
provide production, fulfillment, optimization, analytics, and reporting
services. Our service providers will be given access to your information only as
is reasonably necessary to provide the services for which they are contracted.

Successors. If we sell or otherwise transfer part or all of our business or
assets to another organization, such as in the course of an acquisition, merger,
bankruptcy or liquidation, we may transfer your Personal Information and Usage
Data. In such an event, we will require the buyer or transferee to agree to our
commitments provided in this Privacy Policy.

Legal Process, Enforcement, and Security Notice. We reserve the right to
disclose your Personal Information and Usage Data if we have a good faith belief
that access, use, preservation or disclosure of such information is reasonably
necessary (i) to satisfy any applicable law, regulation, legal process or
enforceable governmental request (such as for example, to comply with a subpoena
or court order), (ii) to detect, prevent, and address fraud or other illegal
activity, and (iii) to investigate, respond to, or enforce violations of our
rights or the security of this site.

When We Participate In a Joint Venture With Marketing Partners. We may
participate with another company or individual for purposes of jointly promoting
our products, services, promotions, or contests or their products, services,
promotions, or contests. We reserve the right to disclose your Personal
Information to them for purposes of (i) compensation, transaction processing,
fulfillment, and support, and (ii) for purposes of offering you other products,
services, promotions, and contests. These joint venture marketing partners may
also contact you regarding other products, services, promotions, or contests.

Disclosures of Personal Information In Our Discretion. If we believe, in our
sole discretion, that it’s reasonable to disclose Personal Information and any
information regarding your use of this site and/or any product, service,
promotion, or contest offered through this site, including any information
regarding other websites that are accessible through this site, we reserve the
unqualified right to do so.

Your California Privacy Rights. Under California Law SB 27, California residents
have the right to receive, once a year, information about third parties with
whom we have shared information about you or your family for their marketing
purposes during the previous calendar year, and a description of the categories
of personal information shared. To make such a request, please send an email to
the email address provided in our contact information below and include the
phrase “California Privacy Request” in the subject line, the domain name of the
Web site you are inquiring about, along with your name, address and email
address. We will respond to you within thirty days of receiving such a request.

SPECIFIC INFORMATION ABOUT COOKIES AND WEB BEACONS

In order to provide better service for our site, we may use Cookies and Web
Beacons to collect Usage Data to store your preferences and information about
what pages you visit and past activity at our site. We may also employ Web
Beacons from third parties in order to help us compile aggregated statistics
regarding the effectiveness of our promotional campaigns or other operations of
our site.

“Cookies” are tiny pieces of information stored by your browser on your
computer’s hard drive. Cookies are also used to customize content based on your
browser. Most browsers are initially set to accept cookies. If you want to
disable cookies, there is a simple procedure in most browsers that allows you to
turn off cookies. Please remember, however, that cookies may be required to
allow you to use certain features of our site.

Flash Cookies – third-party cookies that use an Adobe Flash Media Player local
shared object (LSO) – may be used along with other third-party cookies for
purposes of crediting any purchase you may make on this site to one of our joint
venture marketing partners that may have referred you to us. These cookies will
be used for purposes of crediting sales to the referring joint venture marketing
partner. Flash cookies are not the same as “browser cookies”. The Adobe Flash
Media Player is software that enables users to view content on their computers.
Flash cookies are also accompanied by a browser cookie. If you delete the
browser cookie, the Flash cookie may automatically create (or re-spawn) a
replacement for the browser cookie.

Web Beacons – sometimes called single-pixel gifs or clear gifs – are used to
assist in delivering cookies, and they allow us to count users who have visited
pages of our site. We may include Web Beacons in promotional e-mail messages or
other communications in order to determine whether messages have been opened and
acted upon.

ANALYTICS

We reserve the right to participate with third-party analytics partners to
monitor and analyze Web traffic which can be used to keep track of user behavior
on this site.

Google Analytics (Google) – Google Analytics is a web analysis service provided
by Google Inc. (“Google”). Google utilizes the data collected to track and
examine the use of this site, to prepare reports on its activities, and to share
them with other Google services. Information collected: cookie and Usage Data.
Visit Privacy Policy at https://www.google.com/intl/en/policies/?fg=1 You may
opt out of the Google Analytics service with the Google’s Browser Add-on that’s
available at https://tools.google.com/dlpage/gaoptout/SOCIAL MEDIA INTERACTIONS

We invite you to socialize and share your participation with this site and
purchases. If you choose to use social media platforms such as Facebook,
Twitter, Pinterest, and Instagram, you will be allowing interaction with these
platforms or other external platforms directly from this site, and in the
process, you may be sharing certain profile elements, including your comments.
This sharing is subject to each social media program’s privacy policies.

DO NOT TRACK REQUESTS

Some Web browsers incorporate a “Do Not Track” feature that signals to websites
that you visit that you do not want to have your online activity tracked. Each
browser communicates “Do Not Track” signals to websites differently, making it
unworkable to honor each and every request correctly. In order to alleviate any
communication error between browsers and website, we do not respond to “Do Not
Track” signals at this time. As the technology and communication between browser
and website improves, we will reevaluate the ability to honor “Do Not Track”
signals and may make changes to our policy.

DATA SECURITY

We will implement reasonable and appropriate security procedures consistent with
prevailing industry standards to protect data from unauthorized access by
physical and electronic intrusion. Unfortunately, no data transmission over the
Internet or method of data storage can be guaranteed 100% secure. Therefore,
while we strive to protect your Personal Information by following generally
accepted industry standards, we cannot ensure or warrant the absolute security
of any information you transmit to us or archive at this site.

When you transmit Personal Information through our registration process or if
you purchase products or services, we encrypt that information in transit using
secure socket layer technology (SSL).

After the secure transfer of your Personal Information, the information is
maintained and stored with 128-bit encryption.

ONWARD TRANSFER OUTSIDE YOUR COUNTRY OF RESIDENCE

Any Personal Information that we may collect on this site may be stored and
processed in our servers located in the United States or in any other country in
which we, or our affiliates, subsidiaries, or agents maintain facilities. By
using this site, you consent to any such transfer of Personal Information
outside your country of residence to any such location.

UPDATING PERSONAL INFORMATION

Upon request, we will permit you to request or make changes or updates to your
Personal Information for legitimate purposes. We request identification prior to
approving such requests. We reserve the right to decline any requests that are
unreasonably repetitive or systematic, require unreasonable time or effort of
our technical or administrative personnel, or undermine the privacy rights of
others. We reserve the right to permit you to access your Personal Information
in any account you establish with this site for purposes of making your own
changes or updates, and in such case, instructions for making such changes or
updates will be provided where necessary.

LINKS TO JOINT VENTURE MARKETING PARTNER SITES

This site may contain links to other websites operated by our joint venture
marketing partners. If you do click on any of the links to their websites or
accept any of their promotional offers, your click-through information and any
information that you provide in the process of registration or purchase will be
transferred to these sites. We have no responsibility or liability for the
policies and practices of these sites. You should be careful to review any
privacy policies posted on any of these sites before providing information to
them.

CHILDREN’S ONLINE POLICY

We are committed to preserving online privacy for all of its website visitors,
including children. This site is a general audience site. Consistent with the
Children’s Online Privacy Protection Act (COPPA), we will not knowingly collect
any information from, or sell to, children under the age of 13. If you are a
parent or guardian who has discovered that your child under the age of 13 has
submitted his or her personally identifiable information without your permission
or consent, we will remove the information from our active list, at your
request. To request the removal of your child’s information, please contact our
site as provided below under “Contact Us”, and be sure to include in your
message the same login information that your child submitted.

CONTACT US

If you have any questions regarding this Privacy Policy, please contact the
owner and operator of this website business at:

The Spyrol Group LLC: Privacy Policy Officer
PO Box 1510,
Clearwater, FL, 33757
Email: customerservice@smarttrading.com
Telephone: 918-203-7547

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