Last updated 07/30/2017
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.
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
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.
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:
- - Full name
- - E-mail address
- - Password
- - IP Address
- - Simulation and/or trading strategies
- - Simulation and/or trading results
“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:
- - Browser and device information (e.g., browser/device type, UDID, geographic location, etc.)
- - Information collected through cookies, pixel tags, and other tracking technologies
- - Aggregated or otherwise de-identified information
Stock Circles uses the information collected about you through the Service (including Personal Information) in order to, among other things:
- - Confirm and complete transactions
- - Operate, monitor, manage, improve, and expand the Service and/or its business activities
- - Provide customer service support and other requested information or services
- - Respond to inquiries and resolve problems or disputes
- - Develop, enhance, and market its Service
- - Communicate about your interactions with the Service and your Stock Circles account
- - Provide promotional offers, administrative materials, and other related content
- - Personalize content and experiences on the Service
- - Allow you to participate in sweepstakes, contests, or promotions
- - Facilitate social sharing, messaging, or other similar functionalities on the Service
- - Protect the rights or property of Stock Circles
- - Comply with legal or other regulatory requirements.
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.
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.
OTHER TERMS & CONDITIONS
Please review the User Agreement, which sets out other important terms of your use of the Service.
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.
29315 Stonecrest Rd
Rolling Hills Estates, CA 90275
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.