Privacy Notice


JMWW, Inc, d/b/a Apex Trading, on behalf of its affiliates and subsidiaries (collectively, “Apex Trading,” “us,” “we,” or “our”) has prepared this Privacy Policy (“Privacy Policy”) to describe to you, or if you represent an entity or other organization, that entity or organization (in either case, “you,” or “your”) our online and offline practices regarding the personal information that Apex Trading collects, uses, and shares on behalf of end users (“Users”) of our online informational platform (the “Platform”) accessed through the website located at www.Apex Trading.com, and any other websites operated by Apex Trading (each, a “Site”) (each Site is treated as a part of the “Platform” for purposes of this Privacy Policy). Capitalized terms not defined in this Privacy Policy, shall have the meanings as defined in the Apex Trading Terms of Service, located at Terms of Service .

Apex Trading reserves the right, at any time, to modify this Privacy Policy. If we make revisions that change the way we collect, use, or share personal information, we will post those changes in this Privacy Policy. You should review this Privacy Policy periodically so that you keep up to date on our most current policies and practices. We will note the effective date of the latest version of our Privacy Policy at the end of this Privacy Policy. Your continued use of the Platform following posting of changes constitutes your acceptance of such changes.     


1. COLLECTION OF PERSONAL INFORMATION 

      1.1. Personal Information.  The following are categories (with non-exhaustive examples) of personal information we may collect about you and for each category the purpose for which it may be used:


Categories

Examples

A. Individual Identifiers and Demographic Information

A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, driver’s license number, passport number, or other similar identifiers.

B. Sensitive Personal Information 

Health information, financial or credit/debit card account information, information about children, Social Security number, race/ethnicity, nationality, sexual orientation, political opinions, labor/trade union membership, religious or philosophical beliefs. 

C. Geolocation Data

Precise physical location or movements. 

D. Commercial Information 

Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

E. Internet or Network Activity

Browsing history, search history, information on an individual’s interaction with a website, application, or advertisement.

F. Professional or Employment-Related Information

Information collected in connection with employment or application for employment, benefit information, title, employment history, education, job qualifications, current or past job history, performance evaluations, and other employee personal data.

G. Education Information 

Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

H. Inferences Drawn from Personal Information

Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.


     1.2. Sources of Personal Information. We obtain the categories of personal information listed above on or through our Platform from the following categories of sources:

2. USE OF PERSONAL INFORMATION

Apex Trading’s primary purpose in collecting personal information is to provide the Services and Content that you request on the Platform. Apex Trading may also use personal information for various purposes, including without limitation to:




3. SHARING OF PERSONAL INFORMATION 

In addition to the specific situations discussed elsewhere in this Privacy Policy, Apex Trading may share your personal information in the following circumstances: 

     3.1. Related Companies and M&A Transactions. We may share your personal information with companies that are affiliated with us (that is, that control, are controlled by, or are under common control with us). In addition, if we sell all or part of its business or make a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer your personal information to a third party as part of that transaction, including at the negotiation stage.

     3.2. Consent. We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Privacy Policy, and we may do so with your consent.

     3.3. Legal Compliance. We may disclose personal information in response to subpoenas, warrants, or court orders, in connection with any legal process, or to comply with relevant laws. We may also share your personal information in order to establish or exercise our rights; to defend against a legal claim; to investigate, prevent, or take action regarding possible illegal activities or fraud; to protect the safety and security of other Users; or to prevent a violation of our Terms of Service

     3.4. Service Providers. We may share your personal information with third parties who perform services on our behalf that are necessary for the orderly operation of the Platform. Among other things service providers may help us perform website hosting, app design, maintenance services, database management, web analytics, app analytics, billing, payment processing, fraud protection, credit risk reduction, marketing, or any other use set out in this Privacy Policy. Access to your personal information by these service providers is limited to the information reasonably necessary for the service provider to perform its limited function. We require our service providers to keep the personal information that they are provided with confidential and to comply with all applicable laws. 

     3.5. Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Platform so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Platform, or on other websites. 

     3.6. Partner or Client Offerings. We may jointly offer events, promotions, or any other product or service offerings with third party partners or our clients, which may be your employer. The personal information that you submit through an event, promotion, or other product or service offering may be combined and transmitted with the Registration Information related to your Account. Third party partners or clients may collection information directly from you, which may be combined with personal information disclosed by us. If you decide to request, enter into, or participate in an event, promotion, or other product or service offering that is offered by us and identified as a joint effort with a third-party partner or client, the information that you provide may be shared with us and with that identified third party. 

     3.7. Social Networking. The Platform may offer you the ability to share your personal information through a social networking website (e.g., Facebook, Twitter), using such site’s integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). The use of such integrated tools enables you to share personal information about yourself with other individuals or the public, depending on the settings that you have established with such social networking site. For more information about the purpose and scope of data collection and use in connection with such social networking site or a site’s integrated tools, please visit the privacy policies of the entities that provide these social networking sites.

     3.8. Public Forum and Messaging. The Platform may provide you with the opportunity to post comments, messages, or reviews in a public forum. If you decide to submit personal information at these locations, that information will be available to other Users of the Platform.

     3.9. Referrals. Users may recommend other Users to join the Platform by providing their contact information or selecting friends from a social networking site. Users may also provide information about other Users of the Platform such as reviews of the services or products that he or she received, or reference information.


4. SECURITY OF PERSONAL INFORMATION 

No method of transmission over the Internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from the risks presented by unauthorized access or acquisition, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of any unauthorized access or acquisition of your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law. 


5. YOUR CHOICES 

You can make the following choices regarding your personal information:

     5.1. Access to Your Personal Information. You may request access to your personal information by contacting us as described below. We will grant you reasonable access to the data that we have about you as required by law. 

     5.2. Changes to Your Personal Information. We rely on you to update and correct the personal information contained in your Account. Note that we may keep historical information in our backup files as permitted by law. If our Platform does not permit you to update or correct certain personal information, please contact us as described below.

     5.3. Deletion of Your Personal Information. Typically, we retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law. You may, however, request that we delete your personal information by contacting us contacting us as described below. We will grant a request to delete information as required by law, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another one of our business purposes. Except as provided above, we will delete, aggregate, or de-identify all of your personal information as described in this subsection within the timeframes required by law.


6. OPTING OUT

You can make the following choices to opt out of certain activities regarding your personal information:

     6.1. Promotional E-mails. You may choose to provide us with your e-mail address for the purpose of allowing us to send newsletters, surveys, offers, and other promotional materials related to our Platform, as well as targeted offers from third parties. You can stop receiving promotional e-mails by clicking the “unsubscribe” links in the e-mails or by contacting us as described below. If you decide not to receive promotional e-mails, we may still send you service-related communications, such as those about your Account, to fulfill orders for products and service you have requested, or deliver notifications directly to you through the Platform.


     6.2. Behavioral-Based Advertising. We participate in behavioral-based advertising. This means that a third party may use technology (e.g., a cookie) to collect information about your use of our Platform so that we can provide advertising about products and services tailored to your interest. That advertising may appear either on our Platform, or on other websites. If you wish to limit third parties’ collection of information about your use of our Platform, you can opt-out of such at the Digital Advertising Alliance in the US, the Digital Advertising Alliance of Canada in Canada, or the European Digital Advertising Alliance in Europe. PLEASE NOTE THAT OPTING-OUT OF BEHAVIORAL ADVERTISING DOES NOT MEAN THAT YOU WILL NOT RECEIVE ADVERTISING WHILE USING THE PLATFORM. IT WILL, HOWEVER, EXCLUDE YOU FROM INTEREST-BASED ADVERTISING CONDUCTED THROUGH PARTICIPATING NETWORKS, AS PROVIDED BY THEIR POLICIES AND CHOICE MECHANISMS.  


     6.3. Do-Not-Track. Some web browsers and devices permit you to broadcast a preference that you not be “tracked” online. At this time, we do not modify your experience based upon whether such a signal is broadcast.


7. EXERCISING YOUR PRIVACY RIGHTS

When exercising the rights or options described in this Privacy Policy, the following guidelines apply:

    7.1. No Fee Usually Required. You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee or decline to comply with your request if your request is clearly unfounded, repetitive, or excessive.

     7.2. What We May Need from You. When exercising your rights or otherwise assisting you, we may need to request specific information from you to help us confirm your identity. This is a security measure to ensure we do not disclose personal information to any person who is not entitled to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

     7.3. Time to Respond. We try to respond to all legitimate requests within 30 days of your request. Occasionally it may take us longer than 30 days to respond, for instance if your request is particularly complex or you have made a number of requests. In this case, we will notify you of the delay, and may continue to update you regarding the progress of our response.

     7.4. No Discrimination. You will not be subject to discrimination as a result of exercising the rights described herein. In some cases, when you exercise one of your rights, we will be unable to comply with the request due to legal obligations or otherwise, or we will be unable to provide you certain products or services. These responses are not discrimination and our reasons for declining your request or ceasing services will be provided at that time.

     7.5. Authorized Agent. You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s identification information, and the authorized agent’s identification information.


8. CONTACTING US

If you have any questions or concerns about our aPrivacy Policy or any other privacy or security issue, please contact us at:

Apex Trading

Attn: Apex Trading Privacy Agent

3303 N. Mississippi Avenue, Suite 503

Portland, OR 97227

support@ApexTrading.com


Effective Date: March 24, 2020