SaberTrade | Privacy

SABERTRADE INC.

SaberTrade Inc., together with its affiliates and subsidiaries (collectively, “SaberTrade” “we”, “us” or “our”) allows, via our website (the “Website”), publishers and content creators (collectively, the “Publishers”), who provide content related to various trading/investment news, outlooks, and ideas, to create custom embedded links (“SaberTrade Links”) with various trading selections which, if clicked on by individual consumers (the “Traders”), will direct such Traders to SaberTrade’s platform (the “Platform”). The Platform then directs the Trader to their preferred trading brokerage where the Trader can then execute their intended trade. The forgoing shall collectively be referred to herein as the “Services”. Further, Traders and Publishers using our Services are collectively referred to herein as “you”, “your”, or “user”.

This privacy policy (this “Privacy Policy”) sets forth our policy with respect to information, collected from you on or through the Services that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with you (“Personal Data” or “Personal Information”). We take the privacy of your Personal Data seriously. Because of that, we have created this Privacy Policy. By using the Services or interacting with us, you are agreeing to this Privacy Policy. Please read the following carefully to understand how we collect, use, disclose, and maintain information that can be used to identify you. In addition, this Privacy Policy describes your choices for use, access, and correction of your Personal Data. If you do not agree to be bound by this Privacy Policy, please stop using the Services.

1. Changes to this Privacy Policy. We may change this Privacy Policy from time to time. In the event we make changes, we will notify you by revising the “Last Updated” date at the top of this Privacy Policy. If there are significant changes to this Privacy Policy, we will attempt to notify you directly by email or provide information via our home page prior to such changes becoming effective. We encourage you to review our Privacy Policy whenever you use the Services to stay informed of ways you can protect your privacy.

2. Information We Collect and Receive. When you use or interact with us through the Services, we may collect certain information, including Personal Data. More information about the categories and sources of information are provided below.
2.1 Information You Provided to Us.We collect information that you decide to share with us. At times, we may require you to provide certain information in order to use certain parts of our Services, fulfill your requests, or provide you with certain services.
2.1.1 Account Information.When you create an account, you may provide your name, email address, phone number, physical address, and any other information you choose to upload to your account.
2.1.2 Banking Information. When Traders utilize a SaberTrade Link within a Publisher’s content, the Publisher may receive a commission payment. All commission payments are remitted to the Publisher by Stripe, Inc., our third-party payment processor (the “Payment Processor”). As such, we will not collect or process Publishers’ bank account information and/or PayPal information. For avoidance of doubt, when a Publisher is receiving a commission payment via the Payment Processor, we will not have access to the Publishers bank account information and/or PayPal information, thus we have no control over, and are not responsible for, any of the Payment Processor’s use of a Publisher’s bank account information and/or PayPal information. For more information on the types of information collected by the Payment Processor, please view their applicable privacy policy prior to submitting your bank account information and/or PayPal information.
2.1.3 Content. When Publishers via our Website create a SaberTrade Link, the Publisher will provide certain information, including, but not limited to where the Content will be published and the trading/investment selection to be embedded within the SaberTrade Link. Further, if we publish/post a Publisher’s content to our Website, we may gather various information, including Personal Data, from the content itself.
2.1.4 Social Media Data. We have pages on social media Services like Facebook, Twitter, Instagram, and LinkedIn (“Social Media Pages”). When you interact with our Social Media Pages, we will collect Personal Data that you elect to provide to us, such as your contact details and messages sent. In addition, the companies that host our Social Media Pages may provide us with aggregate information and analytics regarding the use of our Social Media Pages.
2.1.5 Contacting Us. You may interact with us through our Services, including through any interactive feature, online contact form, email, or any other communication mechanism. When using these channels, you typically provide your account information and any other information you choose to provide us at your option.
2.1.6 Surveys. When you complete any forms or respond to a survey or questionnaire, we collect the Personal Data you provide.
2.2 Information We Obtain from Others. We may obtain information about you from third parties who help us provide our Services to you and from publicly available sources. We may also obtain some information from our marketing partners in order to inform you about Services or products that we think you might be interested in. Finally, we may obtain information that does not identify you directly, but which is later used in a way that may later directly identify you. We may combine that general information with your information to provide related services to you.
2.3 Information We Automatically Collect. We automatically collect certain information from you when you use the Services, such as when you click on a SaberTrade link and subsequently execute a trade through your preferred brokerage, including internet or other network activity information such as your Internet Protocol (“IP”) address, unique device identifiers, browsing and search history, and cookies and other technologies.
2.3.1 Log Information. We retain information about you when you click on a SaberTrade Link or otherwise access and use the Services. This information can include the following: IP address, timestamps, browser information, Internet Service Provider (“ISP”), web pages visited, and URL of the webpage you visited before navigating to our Services.
2.3.2 Device Information. We monitor user activity when you click a SaberTrade Link or otherwise in connection with your use of the Services and may collect information about the applications and features you use, websites and trading brokerages you visit, as well as types and amount of Services you use.
2.3.3 Location Information. When using the Services, we may collect and process certain location-based information, including geolocation data, from your mobile device or web browser, to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device's settings.
2.3.4 Crash and Error Information. If the Services crash or return an error, we may collect data to determine the cause of the error using first- or third-party services. The crash or error information collected may include the following: device IP address, device name, operating system version, application configurations(s), the time and date, and other statistics.
2.3.5 Cookies and Other Technologies. Cookies and similar technologies (e.g. pixels and ad tags) (collectively, “Cookies”) are small files which, when placed on your device, enable us to collect certain information, including Personal Data, from you in order to provide certain features and functionality. We and our service providers and business partners use Cookies to collect data and recognize you and your device(s) on the Services and elsewhere across your different devices. We do this to better understand the effectiveness of the advertising on the Services and to enhance your user experience.
2.3.6 Analytics. We may also use Google Analytics and other service providers to collect information regarding visitor behavior and visitor demographics on our Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Service by going to http://tools.google.com/dlpage/gaoptout.

3. How We Use Your Information.
3.1 Use of Your Information. We may use your Personal Data for our legitimate interests and the limited purpose of providing the Services and related functionality and services, as described in the Terms of Service (the “Terms”) and in this Privacy Policy, and as permitted by applicable laws. These purposes include circumstances where it is necessary to provide or fulfill the Services requested by or for you or where you have given us your express consent. We may use your Personal Data as follows:
(i) To register you as a user of the Services and to create a profile about you to help us personalize our services to you;
(ii) To provide the information and services you request;
(iii) To provide you with effective customer service;
(iv) To provide you with a personalized experience when you use our Services;
(v) To send administrative information to you, for example, information regarding the Services and changes to our Terms, conditions, and policies;
(vi) To invite you to participate in surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us);
(vii) To better understand your needs and interests;
(viii) To improve our Services and develop new Services;
(ix) To improve our marketing and promotional efforts;
(x) To improve the functionality and usability of the Website, Platform, and SaberTrade Links;
(xi) To prevent spam, fraud, abuse, criminal activity, or misuses of our Services, to enforce our Terms, and to ensure the security of our IT systems, architecture, and networks;
(xii) To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties; and
(xiii) For use for any other purpose for which we provide notice at the time of collection.
3.2 With Your Consent.
In some cases, we’ll ask for consent to use your Personal Data for specific purposes. If we do, we’ll make sure you can revoke your consent in in accordance with the “Your Choices” section below.
3.3 Other Purposes.
If we intend to use any Personal Data in any manner that is not consistent with this Privacy Policy, you will be informed of such anticipated use prior to or at the time the Personal Data is collected, or we will obtain your consent subsequent to such collection but prior to such use.
3.4 Aggregated Personal Data.
In an effort to understand and serve our users better, we may conduct research on our customer demographics, interests, and behaviors using aggregated and/or de-identified information collected through the Services and from other sources so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”).

4. How We Share and Disclose Information.
4.1 Service Providers and Business Partners.
To assist us in meeting business operations needs and to perform certain services and functions, we may share Personal Data with service providers and business providers, including providers of website and/or platform hosting, Services-related consulting and monitoring, data analysis, information technology and related infrastructure provision, customer service, email delivery, auditing, and other services related to delivering the Services. Pursuant to our instructions, these parties will access, process, or store Personal Data in the course of performing their duties to us. We take commercially reasonable steps to ensure our service providers adhere to the security standards we apply to your Personal Data.
4.2 Sharing You Control.
We may share or disclose your Personal Data for other purposes pursuant to your consent or with your further direction.
4.3 Disclosure and Sale of Personal Data.
We may disclose, share, or sell your Personal Information to various third-parties, such as advertising and marketing firms, publishers, trading firms, data brokers, and AI firms, for such third-parties’ business and commercial purposes, including, but not limited to, enabling and improving their marketing and advertising campaigns, identifying potentially interested consumers, and measuring the effectiveness of the marketing and advertising campaign.
4.4 Other Applications.
You may have the ability connect via the Services with other third-party services. By doing so, you’re enabling us and those third parties to exchange Personal Data about you so that we and those third parties can provide, improve, protect, and promote such services. Please remember that third parties’ use of your Personal Data will be governed by their own privacy policies and terms of service.
4.5 Aggregate/De-Identified Data.
From time to time, we may share Aggregate/De-Identified Information about use of the Services, such as by publishing a report on usage trends. The sharing of such data is unrestricted.
4.6 Legal Reasons.
We may also disclose your Personal Data when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose your Personal Data to prevent or investigate a possible crime, such as fraud or identity theft; to protect the security of our Services; to enforce or apply our policies or other agreements; or to protect our own rights or property or the rights, property or safety of our users or others. We will attempt to notify our users about legal demands for their Personal Data when appropriate in our judgment unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague, or lack proper authority.
4.7 Sale, Merger, or Other Business Transfer.
As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), Personal Data may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third-party, your Personal Data would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.

5. Your Choices.
(a) If you have registered for an account, you may access, review, update, or delete certain Personal Data that you have provided to us by logging into your account and using available features and functionalities or by contacting us in accordance with the “Contact Us” section below. You may also contact us to delete your account. Please note that we will need to verify that you have the authority to delete the account and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy.
(b) Most web browsers are set to accept Cookies by default. If you prefer, you can usually set your browser to remove or reject Cookies. Please note that if you choose to remove or reject Cookies, this could affect the availability and functionality of our Services.
(c) You have a choice at any time to stop us from sending you emails for marketing purposes by following the “unsubscribe” link included in these messages. Please note that despite any indicated email marketing preferences, we may continue to send you administrative emails, including, for example, notices of updates to our Terms or this Privacy Policy, if we choose to provide such notices to you in this manner.
(d) In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features. We will tell you what Personal Data you must provide in order to receive the Services.
(e) Some browsers offer a “do not track” (“DNT”) option. Since no common industry or legal standard for DNT has been adopted by industry groups, technology companies, or regulators, we do not respond to DNT signals. We will make efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

6. European Residents.
If you are a resident of the European Economic Area, we rely on our legitimate interest as described in this Privacy Policy to process your Personal Data. Additionally, subject to any exemptions as provided by law, you may have certain rights regarding the Personal Data we maintain about you. We offer you certain choices about what Personal Data we collect from you, how we use that information, and how we communicate with you. If at any time you wish to exercise your rights, please reach out to us in accordance with the “Contact Us” section below.
6.1 Right of Access.
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.
6.2 Right to Rectification.
If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it.
6.3 Right to Erasure.
You may ask us to erase your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable) and where there is no other legal basis for processing.
6.4 Right to Restrict Processing.
You may ask us to restrict or ‘block’ the processing of your Personal Data in certain circumstances, such as if you contest its accuracy or object to us processing it.
6.5 Right to Data Portability.
You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and if the processing is carried out by automated means.
6.6 Right to Object.
You may ask us at any time to stop processing your Personal Data, and we will do so: (a) if we are relying on a legitimate interest to process your Personal Data, unless we demonstrate compelling legitimate grounds for the processing or your data is needed to establish, exercise, or defend legal claims; or (b) we are processing your Personal Data for direct marketing and, in such case, we may keep minimum information about you (for example, in a suppression list) as necessary for our and your legitimate interest to ensure your opt out choices are respected in the future and to comply with data protection laws.
6.7 Right to Withdraw Consent.
If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
6.8 Right to lodge a Complaint.
If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

7. Additional Information for Residents of Certain US States.
7.1.1
If you are a resident of the State of California, you may have certain rights afforded to you under the California Consumer Privacy Act or the “CCPA”, as amended by the California Privacy Rights Act.
7.1.2
We collect Personal Information for the business and commercial purposes described in the section above titled “How We Use Your Information”, and we share Personal Information with the categories of third parties described in the section above titled “How We Share and Disclose Information”. Please note that we do use third-party Cookies for our advertising purposes as further described in the section above titled “Information We Automatically Collect”.
7.1.3
We have sold or shared, or may sell or share Trader’s personal identifiers, specifically limited to the Trader’s IP address. For avoidance of doubt, we have not sold or shared, and will not sell or share, a Trader’s name, email address, or phone number.
7.1.4
The following are the categories of third-parties with which Personal Information is, or may be, sold or shared to: (i) services-professionals (for example, advertising and marketing agencies); (ii) business services/agencies (for example, data brokers and AI firms); and financial services (for example, trading firms).
7.1.5
(i) You may have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices.
(ii) You may have the right to request that we delete your Personal Information that we have collected from you.
(iii) You may have the right to request that we correct inaccurate Personal Information.
(iv) You have the right to opt-out of sale or sharing of your Personal Information.
(v) You may have the right to exercise control over our collection and processing of certain sensitive Personal Information (as defined in the CCPA).
(vi) You have the right not to receive retaliatory or discriminatory treatment for exercising these rights.
7.1.6
To request access to or deletion of your Personal Information, or to exercise any other privacy rights under California law, please contact us at Privacy@Saber-Trade.com, or via any other method which may be specified in the “Contact Us” section below. In order to verify your request to know or delete certain Personal Information, we may require you to provide us with certain information to be used solely for the purpose of verifying your identity.
7.1.7
Specifically, to take advantage of your right to opt-out of the sale or sharing of your Personal Information, please click here, or select the link in the footer of our Website titled “Do Not Sell of Share My Personal Information”, or contact us using the Contact Us section below.
7.1.8
Under the CCPA, you may exercise these rights yourself or you may designate an authorized agent to make these requests on your behalf. We may request that your authorized agent have written permission from you to make requests on your behalf and may need to verify your authorized agent’s identity.
7.2 Additional information for Colorado Residents (Effective July 1, 2023).
7.2.1
The Colorado Privacy Act, if applicable to us, provides some Colorado residents with the rights listed below:
7.2.2
We have sold or shared, or may sell or share Trader’s personal identifiers, specifically limited to the Trader’s IP address. For avoidance of doubt, we have not sold or shared, and will not sell or share a Trader’s or Publisher’s name, email address, or phone number.
7.2.3
We may disclose, share, or sell your Personal Data to various third-parties, such as advertising and marketing firms, publishers, trading firms, data brokers, and AI firms, for such third-parties’ business and commercial purposes, including, but not limited to, enabling and improving their marketing and advertising campaigns, identifying potentially interested consumers, and measuring the effectiveness of the marketing and advertising campaign.
7.2.4
To request access to or deletion of your Personal Data, or to exercise any other privacy rights under Colorado law, please contact us at Privacy@Saber-Trade.com, or via any other method which may be specified in the “Contact Us” section below.
7.2.5
Specifically, to take advantage of your right to opt-out of the sale or sharing of your Personal Data, please click here, or select the link in the footer of our Website titled “Do Not Sell of Share My Personal Information”, or contact us using the Contact Us section below.
7.2.6
Please note that to respond to some rights we may need to verify your request either by asking you to log in and authenticate your account or otherwise verify your identity by providing information about yourself or your account. Authorized agents can make a request on your behalf if you have given them legal power of attorney or we are provided proof of signed permission, verification of your identity, and, in some cases, confirmation.
7.3 Additional information for Connecticut Residents (Effective July 1, 2023).
7.3.1
The Connecticut Data Privacy Act, if applicable to us, provides some Connecticut residents with the rights listed below:
(i) You may have the right to know and see what Personal Data we have collected about you in a portable format.
(ii) You may have the right to request that we correct inaccurate Personal Data.
(iii) You may have the right to request that we delete the Personal Data we have collected about you.
(iv) You may have the right to opt out of targeted advertising (as defined under Connecticut law).
(v) You may have the right to opt out of the sale of your Personal Data.
7.3.2
To request access to or deletion of your Personal Data, or to exercise any other privacy rights under Connecticut law, please contact us at Privacy@Saber-Trade.com, or via any other method which may be specified in the “Contact Us” section below.
7.3.3
Specifically, to take advantage of your right to opt-out of the sale of your Personal Data, please click here, or select the link in the footer of our Website titled “Do Not Sell of Share My Personal Information”, or contact us using the “Contact Us” section below.
7.4 Addition Information for Nevada Residents (Effective October 1, 2019).
7.4.1
If you are a Nevada resident, under Privacy and Security of Personal Information Chapter of the Nevada Revised Statutes Section 603A (“603A”), we are required to provide you with the following:
(i) We may collect certain covered information, i.e., personally identifiable information, as further defined under Nevada law, when you use or visit our Services, including, but not limited to first and last name, home or other physical address, electronic email address, and telephone number.
(ii) We may share your covered information to third parties as described in the section above titled “How We Share and Disclose Information”.
(iii) Third parties may collect covered information about your online activities over time and across different internet websites or online services when you use our Services.
7.4.2
Under Nevada law, certain Nevada consumers may opt out of the sale of their covered information for monetary consideration (as such terms are defined under Nevada law) to a person for that person to license or sell such information to additional persons.
7.4.3
Specifically, to take advantage of your Right to Opt-Out of the Sale of your “covered information”, please click here, or select the link in the footer of our Website titled “Do Not Sell of Share My Personal Information”, or contact us using the “Contact Us” section below. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.
7.5 Additional information for Utah Residents (Effective December 1, 2023).
7.5.1
If you are a Utah resident, pursuant to the Utah Consumer Privacy Act, we must share with you that:
(i) We collect Personal Data for the business and commercial purposes described in the section above titled “How We Use Your Information”;
(ii) We may share your Personal Data to third parties as described in the section above titled “How We Share and Disclose Information”; and
(iii) We collect the categories of Personal Data described in the section above titled “Information We Collect and Receive”.
7.5.2
Utah law, if applicable to us, provides some Utah residents with the rights listed below:
(i) You may have the right to know and see what Personal Data we have collected about you in a portable format.
(ii) You may have the right to request that we delete the Personal Data we have collected about you.
(iii) You may have the right to opt out of targeted advertising (as defined under Utah law).
(iv) You may have the right to opt out of the sale of your Personal Data.
7.5.3
To request access to or deletion of your Personal Data, or to exercise any other privacy rights under Utah law, please contact us at Privacy@Saber-Trade.com, or via any other method which may be specified in the” Contact Us” section below.
7.5.4
Specifically, to take advantage of your right to opt-out of the sale or sharing of your Personal Data, please click here, or select the link in the footer of our Website titled “Do Not Sell of Share My Personal Information”, or contact us using the Contact Us section below.
7.6 Additional information for Virginia Residents (Effective January 1, 2023).
7.6.1
If you are a Virginia resident, pursuant to the Virginia Consumer Privacy Act, we must share with you that:
(i) We collect Personal Data for the business and commercial purposes described in the section above titled “How We Use Your Information”;
(ii) We may share your Personal Data to third parties as described in the section above titled “How We Share and Disclose Information”; and
(iii) We collect the categories of Personal Data described in the section above titled “Information We Collect and Receive”.
7.6.2
Virginia law, if applicable to us, provides some Virginia residents with the rights listed below:
(i) You may have the right to know and see what Personal Data we have collected about you.
(ii) You may have the right to request that we correct inaccurate Personal Data.
(iii) You may have the right to request that we delete the Personal Data we have collected about you.
(iv) You may have the right to opt out of targeted advertising (as defined under Virginia law).
(v) You may have the right to opt out of the sale of your Personal Data.
7.6.3
To request access to or deletion of your Personal Data, or to exercise any other privacy rights under Virginia law, please contact us at Privacy@Saber-Trade.com or via any other method which may be specified in the “Contact Us” section below.
7.6.4
Specifically, to take advantage of your right to opt-out of the sale or sharing of your Personal Data, please click here, or select the link in the footer of our Website titled “Do Not Sell of Share My Personal Information”, or contact us using the Contact Us section below.

8. Security.
We take reasonable precautions intended to help protect your Personal Data that we collect. Unfortunately, no system or online transmission of data is completely secure, and we cannot guarantee the security of data transmitted across the Internet. If you believe that information you provided to us is no longer secure, please notify us immediately using the contact information provided below.

9. Information Retention.
We will retain Personal Data required to comply with privacy requests, manage active accounts, as required by law, in order to resolve disputes, or enforce our agreements. We will retain the Personal Data we process on behalf of our users as directed by them. We may also retain copies of your Personal Data for disaster recovery purposes, to prevent fraud or future abuse, or for legitimate business purposes.

10. Data Processing and Data Transfers.
To provide you with the Services, we may store, process, and transmit data in the United States and locations around the world—including those outside your country. Your Personal Data, therefore, may be subject to privacy laws that are different from those in your country. Personal Data collected within the European Economic Area may, for example, be transferred to and processed by third parties located in a country outside of the European Economic Area. In such instances, we shall ensure that the transfer of your Personal Data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place.

11. Links to Third-Party Websites.
The Services may contain links to other websites not operated or controlled by us, including social media services (“Third Party Websites”). The information that you share with Third Party Websites will be governed by the specific privacy policies and terms of service of such Third Party Websites and not by this Privacy Policy. By providing these links we do not imply that we endorse or have reviewed these websites. Please contact the Third Party Websites directly for information on their privacy practices and policies.

12. Children’s Information.
The Services are directed to individuals at the age of eighteen (18) and over. We do not knowingly collect Personal Data from individuals under the age of 18. If we become aware of individuals who have provided us with Personal Data and are under the age of 18, we will take steps to deactivate the account and delete the Personal Data. If you become aware of information from individuals under the age of 18 which has been provided to us, please contact us in accordance with the “Contact Us” section below.

13. Contact Us.
If you have any questions or concerns about our Privacy Policy, please contact us via email at Privacy@Saber-Trade.com.

[End of Privacy Policy]

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