Privacy Policy

In brief: We are KTS Trading, LLC (“Company”, “we”, “us” or “our”). We respect your privacy and work hard to protect the confidentiality of information that you give us. This policy describes the types of information we may collect from you or that you may provide when you visit the https/KTStrading.com website, the KTS Discord Channel, or use the Jarvis Indicator (collectively, the “Services”) and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

· through the Services;

· in email, text, and other electronic messages between you and Company; and

· any other sources.

It does not apply to information collected by:

· us offline or through any other means, including on any other website operated by us or any third party; or

· any third party, including through any application or content (including advertising) that may link to or be accessible from or through the website or through the other Services.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use the Services. By accessing or using the Services, you agree to this privacy policy. This policy may change from time to time (see Updates). Your continued use of the Services after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

We will share your personal data with third parties only in the event that it’s needed for the provision of services and data you have requested (explained in detail in this privacy policy).

Updates

We may update this privacy policy at our discretion from time to time by posting a new version on our website. You should check our website occasionally to ensure any changes are suitable for you.

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The current version of this privacy policy was modified on: 5/15/24

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Personal Data That We Collect

· User Accounts: If you decide to create an account with us, you will need to provide us with some personal data so we can provide you with the services. Currently, during the registration you will be required to provide:

o Email

o Username

o First name

· Orders: When you make a purchase or attempt to make a purchase through the website, we collect certain information from you, including your full name, billing address, payment information (including credit card numbers, email address, and phone number). This information is collected by our payment processor and solely kept for billing purposes.

· Contact Data: We might process any personal data you provide us when communicating with us via email, live chat or phone for the purpose of better assisting you.

· Cookies and other technologies. Correspond to data files that are placed on your browser and often include anonymous unique identifiers.

· Log Files: Correspond to user actions upon interacting with the website or mobile app. This is used to understand how users use the product for us to better the services or to assist a user with any issues they encounter.

· Device Information: We collect the following information about the devices you use to interact with our services: IP address of the device (from which we can also infer the country you are connecting from), operating system, and browser version. We collect this information to prevent spam and abuse of our services. IP addresses may be considered personal data in certain jurisdictions, and will be treated in accordance with this privacy policy.

· Analytics: When you are using the Services, or widgets we provide to another site, we may collect analytics information automatically. This information may include your general device information, device identifiers (for example, Google Advertising ID, if you are using an Android device, or Advertising Identifier (IDFA), if you are using an iOS device), network information, website, and application interaction events. We collect pseudonymous data only and this analytic information does not include any personal identifiable information from your profile. We use this information to analyze and improve the work of our services and applications, and to develop, test, and improve our service further. For this purpose, we may use internal analytics as well as third-party service providers. For further details about our use of third-party service providers, please refer to the Analytics Providers section below.

How Do We Use Your Personal Information?

We will process your personal data as necessary for certain legitimate business interests, which include the following:

Profile. The set of information that corresponds to each individual product usage preference, user settings (such as but not limited to charts, privacy, portfolio, reports, trade grouping, fees, spreads, widgets, and more). This information is kept solely for the purpose of customizing the user’s experience when using the Services, applications, or user account. We do not share private settings with any third party.

User Account and Profile Operations. We use your contact details, such as username, email address, and first name, in the following ways:

· to authenticate your user account, ensure its security along with the security of our services, and to prevent spam, fraud, and abuse;

· to acknowledge, confirm, and deal with your user account;

· to send all new users a welcome activation email to verify their email address;

· (for paid users) to provide you with subscription services and contact you regarding your use of such services. This is necessary for us to implement your requests; and

· paid users will also receive a notification email from Stripe if there are any issues regarding billing their cards for auto-renew subscriptions. Users cannot opt out of these messages, though they can delete their accounts.

User Account Deleting. You may refuse to use the Services and may ask us to delete your account in the Profile settings. Your account will be deleted immediately together with any subsequent personal data you have supplied to us, or we have collected. This action is irreversible. Backups from our system might have partial chunks of your personal data. These chunks will be deleted automatically 30 days after the deletion took place.

Customer Service. When you contact our customer service team, we might use the data that we have collected from you, together with any extra information you might have provided to customer service to properly solve any issues you might encounter.

API. If you are using our API (Application Programming Interface) services (such as importing trades and exporting reports), then we may process your personal data in order to provide and support those services.

When Would We Share Personal Information?

We may disclose aggregated information about our users without restriction.

We share your personal data with third parties in the following situations:

· Payment Information. Paid users must provide payment information (name, payment card information, full address and phone number). This information is used for billing purposes and only processed by our payment processor.

· Company-Affiliated Business. We share the unique anonymous id of the transaction to track referrals.

· Analytics Providers. We might use third-party service providers to monitor and analyze the use of our services and mobile applications.

· Google Analytics. We might use Google Analytics on the website and in conjunction with the widgets we provide. For more information on Google Analytics privacy practices, you can visit https://policies.google.com/privacy.

We share personal information to analytics services for mobile applications that we might use:

· Firebase. A development and analytical platform provided by Google. For more information on what type of information is collected, please visit the Google Privacy web page.

· Business transfer. If we sell our business or our company assets are acquired by a third party, personal data held by us about our general account users, subscription account users or customers may be one of the transferred assets.

· Administrative and legal reasons. If we need to disclose your personal data to comply with a legal obligation and/or judicial or regulatory proceedings, a court order or other legal process, to enforce our Terms and Conditions or other applicable contract terms that you are subject to, or to protect us or our contractors against loss or damage. This may include

but is not limited to, exchanging information with the police, courts or law enforcement organizations.

· Advertising. We might use remarketing and tracking features. Remarketing allows us to display advertising in a more targeted manner in order to present advertisements of interest to users, based on their activity on other websites. Tracking features allow us to collect information about ad clicks and impressions and certain actions upon users interacting with our website and mobile application. We might use the following services for advertising, remarketing, and tracking:

· Google Ads. Help serve and measure targeted ads to people looking for similar services as what we provide.

· Facebook Pixel. Help serve and measure ads and build audiences for our advertising campaigns.

· Adroll. Help serve and measure ads and build audiences for our advertising campaigns.

· Bings Ads. Help serve and measure targeted ads to people looking for similar services as what we provide.

We may also disclose your personal information:

· to comply with any court order, law, or legal process, including to respond to any government or regulatory request;

· to enforce or apply our terms of use [Insert as Link to Website’s Terms of Use] and other agreements, including for billing and collection purposes; and

· if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Company, our customers, or others.

We may share personal information with the following parties:

· To our subsidiaries and affiliates.

· Contractors, service providers, and other third parties we use to support our business.

· To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about users of the Services is among the assets transferred.

Note that we do not share any personal information with our advertisers. They can only access statistics that include the number of impressions and clicks their ads have generated.

Public Information on Our Site

Public Profile. Upon creating an account with us, all your information by default is set to private. Meaning no one else has access to view your information. You can decide to share trade(s) with the public if you wish. Upon doing so, anyone could access the trade(s) you decide to share.

You are in control to decide which data points, if any, you would like to share. For example, you can decide to share your profit and loss or just your return %. You can control this under your privacy settings.

Public Content. Our services allow those with a registered user account to share trades with the rest of the internet via our sharing feature.

By using our sharing features, you grant irrevocable, perpetual, and royalty-free license to publish and disclose the content, as well as the username of the author, which makes you identifiable.

Security of Personal Data

We use technical and organizational procedures to protect your personal data and require third parties with whom we work to do the same.

We use Transport Layer Security (TLS) encryption technology in order to protect certain information that you submit to us. This technology protects you from having your information intercepted by anyone while it is being transmitted to us or a payment processor. While on a secure page, such as our order form, the “lock” icon in the browser window is displayed, confirming that a secure and encrypted connection has been established with the website. We work hard to ensure that our service is secure and that we meet industry standards. We also use other safeguards, such as firewalls, authentication systems (i.e., passwords and personal identification numbers), and access control mechanisms to control unauthorized access to systems and data. If you have chosen to create an account, you are responsible for doing everything you reasonably can to keep your access details secret. You must not share these details with anyone else.

We also do our best to protect user information offline. All of our users’ personal information is restricted to our offices. Only employees who need to see the information to perform their jobs are allowed to access it.

The servers that store personal data are located in a secure environment in a locked facility.

We are constantly improving the ways we secure, store, and process the data we collect, including the addition of physical security measures that help us counter unauthorized access to our systems.

Unfortunately, the transmission of information via the Internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the website.

Children and sensitive personal data

The Services and mobile apps are not directed to children under the age of 18. We do not knowingly contact or collect personal information from children under the age of 18. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at info@ktstrading.com.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information. To learn more about consumer privacy rights in Texas and how to exercise them, visit https://www.sos.state.tx.us/privacy.shtml.

Contact Us

For more information about our privacy policy practice, if you have any questions, or if you would like to make a complaint, please contact us at info@ktstrading.com.

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