Last updated 07/30/2017


INTRODUCTION

In November of 1999, Congress enacted the Gramm-Leach-Bliley Act (GLBA). The GLBA requires certain financial institutions, such as investment advisor firms, to protect the privacy of customer information. In situations where a financial institution does disclose customer information to nonaffiliated third parties, other than permitted or required by law, customers must be given the opportunity to opt out or prevent such disclosure. Stock Circles does not share or disclose customer information to non-affiliated third parties except as permitted or required by law.

ACCESS PERSONS

Stock Circles is committed to safeguarding the confidential information of its clients. Stock Circles holds all personal information provided by clients in the strictest confidence and it is the objective of the firm to protect the privacy of all clients. Except as permitted or required by law, the firm does not share confidential information about clients with non-affiliated parties. In the event that there were to be a change in this policy, the firm will provide clients with written notice and clients will be provided an opportunity to direct Stock Circles as to whether such disclosure is permissible.

To conduct regular business, Stock Circles may collect personal information from sources such as:

• Information reported by the application or other information provided by you

• Information about your transactions generated by Smart Auto-Trading

• Information developed as part of analyses or investment advisory services

To administer, manage, service, and provide related services for client accounts, it is necessary for Stock Circles to provide access to customer information within the firm and to nonaffiliated companies, with whom the firm has entered into agreements with. To provide the utmost service, the firm may disclose the information below regarding customers and former customers, as necessary, to companies to perform certain services on the firm’s behalf.

• Information Stock Circles receives from the client on applications (name, email address, order book, performance reports, etc.)

• Information about the client’s transactions with the firm or others (account information, payment history, parties to transactions, etc.)

• Information concerning investment advisory account transactions

• Information about a client’s securities held and transactions initiated by Smart Auto-Trading

INFORMATION SHARING PERMITTED BY LAW

Since Stock Circles shares nonpublic information solely to service client accounts, the firm does not disclose any nonpublic personal information about the firm’s customers or former customers to anyone, except as permitted by law. However, the firm may also provide customer information outside of the firm as required by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas. In the event that the firm has a change to its customer privacy policy that would allow it to disclose nonpublic information not covered under applicable law, the firm will allow its clients the opportunity to opt-out of such disclosure.

Former Customers. Even if we cease to provide you with financial products or services, our Privacy Policy will continue to apply to you and we will continue to treat your nonpublic information with strict confidentiality.

Stock Circles, Inc. (Stock Circles) recognizes the importance of consumer privacy and take this subject matter seriously. This Privacy Policy (the Policy) has been designed in a format that is easy to navigate and read so that you can clearly understand Stock Circles privacy practices with respect to the information collected by Stock Circles Service (the Service). Stock Circles is committed to treating your Personal Information (as defined below) with care and respect.

This Policy — together with the User Agreement, which are incorporated herein by reference — describes how we collect, use, and disclose information on or through the Service. Please note that the Policy does not apply to activities that are “offline” or unrelated to the Service unless otherwise expressly set forth below. By accessing or interacting with the Service, you agree to the terms and conditions of the Policy.

INFORMATION COLLECTED

Stock Circles collect two main types of information through the Service: Personal Information and Other Information.

"Personal Information” refers to information that can be used to contact you or identify you as a particular individual and the data associated with your activity on the Service. The specific kinds of Personal Information we collect through the Service typically when you register. These include:

“Other Information” refers to any information that does not reveal your specific identity or directly relate to you as an individual. Stock Circles collect a number of different types of Other Information through the Service, such as:

INFORMATION USAGE

Stock Circles uses the information collected about you through the Service (including Personal Information) in order to, among other things:

ACCOUNT REVIEW AND REVIEWERS

Your in-market holdings managed by Smart Auto-Trading are continuously monitored by Smart Auto-Trading. Depending on your strategy, trades may be executed in your accounts on a daily, weekly or monthly basis. Smart Auto-Trading processes conduct an ongoing stock screening routine and executes trades based on a variety of factors. Our overall process is monitored and administered by the CEO/CCO and CTO.

CHANGES

Stock Circles may revise and update the Privacy Policy at any time. We will notify you of any changes to our Privacy Policy by posting the new Privacy Policy with the last revised date and providing an alert upon opening the Service. You are advised to consult this Privacy Policy regularly for any changes, as continued use is deemed approval of all changes.

USER ACCOUNT NOTICE

Access to and use of user accounts on the service is restricted to authorized personnel only. Unauthorized persons attempting to access user accounts may be subject to prosecution.

Authorized personnel of Stock Circles may monitor and record all or portions of your account data for quality control, customer service, employee training, security, legal compliance, and other lawful purposes. Your consent will be ongoing and need not be confirmed prior to, or during such monitoring or recording, except to the extent applicable law expressly requires otherwise.

CONSENT

By using the Service, you are consenting to our processing of your information as set forth in this Privacy Policy now and as amended by Stock Circles. “Processing,” means using cookies on a computer/hand held device or using or touching information in any way, including, but not limited to, collecting, storing, deleting, using, combining and disclosing information, all of which activities.

OTHER TERMS & CONDITIONS

Please review the User Agreement, which sets out other important terms of your use of the Service.

CONTACT US

If you have any questions or concerns about this Policy or our privacy practices on the Service, please write to us at:

Stock Circles, Inc.
Attn: Privacy
29315 Stonecrest Rd
Rolling Hills Estates, CA 90275
U.S.A

Please note that e-mail communications are not always secure.

Last updated: July 30, 2017
Effective Date: October 14, 2014
Stock Circles Inc. All rights reserved.