PRIVACY POLICY

Effective Date: 9/1/2019

This Privacy Policy (the “policy”) is applicable to paid subscribers, free  members and visitors (“Members”) of InvestorsObserver and all other websites (each referred to in this privacy policy as a “site”) owned and operated by O2 Media, LLC (collectively or individually referred to as “InvestorsObserver”, “our” or “us”).

Your privacy, and the privacy of all Members is important to us and we are committed to protecting the personal information you choose to share with us. Accordingly, we have adopted the following policy to describe our data collection and privacy practices.

This policy tells you, among other things, what information we may gather from you, how we may use or disclose that information, and how you can exercise your privacy rights. Please read this policy carefully, and feel free to contact us at support@InvestorsObserver.com if you have any questions regarding its contents.

What information do we gather?

InvestorsObserver may obtain three types of information from its members through the site:

  1. registration, subscription, or application data
  2. site usage data
  3. voluntary postings

Registration, Subscription, or Application Data

The only individually identifiable information that InvestorsObserver captures from you is that which you are asked to provide when you register or subscribe. This registration and subscription information includes your name, mailing address, email address, log in credentials, and billing information.  Your payment information is captured by Stripe, Inc. (“Stripe”) through an embedded payment form, and is not shared with O2 Media, LLC or stored on any of our servers or the InvestorsObserver.com website.  The site also allows you to personalize your experience on the site, such as linking your personal investment data to track your portfolio performance (referred to as “application data”).  Should you utilize our custom features and enter application data, that information will be stored in your profile and linked to your account.

Site Usage Data

To improve your experience on our site we may use ‘cookies’.  Cookies are an industry standard and most major websites use them.  A cookie is a small text file that our website sends to your Internet browser for storage on your computer as a tool to remember your preferences.  InvestorsObserver uses cookies to facilitate the login process for you across multiple applications on our sites, to measure traffic on our websites, and to “personalize” your experience as a Member. When you register, InvestorsObserver assigns a unique identifier to you, and we place a cookie on your web browser which will remind our system of that identifier in other areas of our websites, or the next time you visit our site. This cookie allows you to access all of your personalized areas of our websites without having to log on multiple times. We also use cookies to measure activity on our websites. Our plans for improvements and updates are based on which areas of our website are popular and which are not. Everything we learn from these measurements will be used to enrich your experience on our website.

You may refuse the use of cookies by selecting the appropriate settings on your browser, however, please note that if you do this you may not be able to use the full functionality of the InvestorsObserver website.

When you use your site, third parties may use cookies, beacons or similar technologies to provide advertising on our site and to help us analyze user experiences.  Google uses cookies to help serve ads to you based on your visits to our site and across other sites on the Internet.  Cookies enable Google to deliver more relevant ads. Its use of such tracking techniques is subject to Google’s privacy policy.  To learn more about how to opt out of Google’s use of cookies or other identifiers, visit Google’s Ad Settings.  In addition, our website uses third-party services such as Google Analytics, a service which places beacons, cookies or tags on our site and transmits website traffic data to Google servers.  Google Analytics does not identify individual users or associate your IP address with any other data held by Google. We use reports provided by Google Analytics to help us understand website traffic and web page usage. To find out more about how Google uses data when you use our Site and your options for controlling the information collected by Google from this Site, please click here.  You may opt-out of having your activity on the Site made available to Google Analytics by installing the Google Analytics browser add-on, available here.

InvestorsObserver e-mails and website content may contain hyperlinks to other web domains. InvestorsObserver does not control the content or data-collection behaviors of these third-party websites.

Voluntary Postings

InvestorsObserver offers several avenues for Members to volunteer statements, opinions, or other information which may be made available to others on InvestorsObserver’s website. We do not require Members to include personally-identifiable information in these postings. The content of a voluntary posting is the sole responsibility of the Member who posts it.  Voluntary postings by Members become the property of InvestorsObserver and we cannot restrict disclosures of or otherwise guarantee the privacy of any information contained in such postings.

What do we do with Personal Information?

We use your registration, subscription and application data to support our business operations.  Examples include:

  • To establish and manage business relations with you;
  • To respond to inquiries, requests or comments that we receive;
  • To operate, improve and personalize the products and services we offer and improve, diagnose problems with, and administer the website and/or inform you of relevant news related to your customization;
  • To communicate special offers, promotions, newsletters and information about InvestorsObserver;
  • To understand your needs and preferences to market products to you that we believe may be of interest to you;
  • To prevent or investigate activity that we think may be potentially illegal, unlawful, fraudulent or harmful.

Many of the features on InvestorsObserver websites are designed to be “personalized” to meet the needs and interests of our Members. To support this personalization, we need to be able to identify your account each time you log in to an InvestorsObserver website.  We use site usage data to personalize content and remember you, as further described in the section on “cookies” above.

We may combine information about you with information about other users to analyze members’ use of our site in order to improve user experience and to produce metrics and statistical information. For example, we may track the number of our members who view certain pages or use certain features. Such information and aggregated information we derive from individual members’ information, allows us to continue to grow and provide you with timely and useful information through our Site.

How and when we share your information with others?

We share your information for the purposes set forth in this privacy policy with the following categories of recipients:

InvestorsObserver’s related legal entities

Third Party Service Providers

We may employ the service of third-party providers to aid us in certain aspects of our operations (such as the distribution of our email products).  Depending on the services performed, some of these providers may be provided with member information. These contractors would be subject to confidentiality agreements which limit their use and disclosure of all information they obtain through their relationship with us to related business use only, consistent with this policy.

Marketing Partners

InvestorsObserver may also, from time-to-time, send email advertisements or messages on behalf of third-party advertisers and/or InvestorsObserver affiliates to anyone who subscribes to any of our free or paid services. We may share or rent your email address to advertisers who have special offers that may be of interest to you. You may opt-out from receiving third-party promotional messages at any time through an “opt-out ” or “unsubscribe” link at the bottom of any InvestorsObserver promotional email or by contacting our Customer Service Department by telephone at 1-800-698-9101 Monday through Friday between the hours of 8:00 a.m. and 5:00 p.m. EST. or by emailing us at support@investorsobserver.com, .  This opt-out applies prospectively to our third-party email marketing programs.  To opt-out of marketing from third parties that have previously been provided your email, contact them directly.

Co-Registration.

As part of the registration process for certain free services on the InvestorsObserver website, we may offer you the opportunity to take free offers from third-party publishers by checking an “opt-in” box by each offer. If you check any box to receive an offer, your email address will be shared with the appropriate publisher you’ve selected to receive information from.   InvestorsObserver attempts to accept advertising from relevant, responsible advertisers but makes no representation or guarantee about third party co-registration advertisers and you understand if you choose to register with any third-party advertiser on any InvestorsObserver web page or email that the third party is separate from InvestorsObserver and InvestorsObserver is not responsible or liable for any action or omission by the third-party advertiser.

Corporate Changes

.

In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we reserve the right to disclose and transfer information, including personal information, to prospective buyers, sellers, advisors or partners as a transferred asset.

Legal Obligations

.  InvestorsObserver reserves the right to disclose information as required by law, or to the extent that we believe in good faith that such disclosure is legally required or necessary to protect others’ rights or property.

Any Other Person with your Consent

.

How do I change the types of communications that I receive from InvestorsObserver?

InvestorsObserver uses registration and subscription information to maintain records about your use of InvestorsObserver services, and for us to occasionally send you information about products and services that InvestorsObserver offers. You may modify the types of emails you receive at any time by clicking on the “Manage Email and Message Preferences” option at the bottom of each email.  If you do not wish to receive any communication from InvestorsObserver, you may use the “Unsubscribe” link at the bottom of each email.  Please note that even if you unsubscribe from receiving marketing communications by email, we may still send you service communications or important transactional information related to your accounts and subscriptions, consistent with customer support.

If you have not been receiving information from InvestorsObserver or third parties but now wish to receive such information you may “opt in” by sending an email stating such to support@InvestorsObserver.com.

Text message alerts are available to active subscribers of certain InvestorObserver services.  As a subscriber, you may opt-in to receive notifications of newly published trade ideas, position updates (e.g. rolled calls), and position closures from InvestorsObserver Text Alerts through your mobile device.  Message and data rates may apply.  You may opt out at any time by following the “unsubscribe” instructions contained in text messages from InvestorObserver, which will stop receipt of future commercial text messages from us.

How We Respond to “Do Not Track” Signals

Some browsers have an optional Do Not Track (“DNT”) feature that allows you to express your preference regarding tracking of your online activity by websites.  When you choose to turn on the DNT setting in your browser, your browser sends a signal to websites, ad networks, plug-in providers, and other web services you encounter while browsing to stop tracking your activity via cookies or other tracking technologies.  Our Site does not currently respond to DNT browser signals or mechanisms.

California Privacy Rights

Under California’s “Shine the Light” law, California residents who provide personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, once a calendar year, information which includes a list of all third parties to which InvestorsObserver has disclosed personal information, as defined in California Civil Code Section 1798.83 during the preceding year, if any, with other businesses for their own direct marketing uses. If applicable, this information would include the categories of customer information and the names and addresses of those businesses with which we shared customer information for the immediately prior calendar year.  California residents may request this information in writing by contacting us by email at support@InvestorsObserver.com.  In your request, please attest to the fact that you are a California resident and provide a current California address for your response.  Please allow up to thirty (30) days for a response.

What happens to my information if I am no longer a Member?

Former Members’ registration and subscription information is retained unless you ask us to delete it. You may request that your registration or subscription data be deleted from our system by sending a request to support@InvestorsObserver.com.

How is my information protected?

We use an embedded payment form provided by Stripe to capture your credit card information.  Stripe is a certified PCI Service Provider Level 1 which is the most stringent level of certification available in the payment industry.  For more information, please refer to Stripe’s website.   Your credit card data is never captured or stored by InvestorsObserver. All activity on InvestorsObserver.com is transmitted via HTTPS to protect you and your activity including logins and passwords.

Please remember that you play a valuable part in data security as well. Your passwords to access our websites, should never be shared with anyone and should be changed frequently. After you have finished using one or more of our sites, you should log off and exit your browser so that no unauthorized persons can use our sites under your name and account information. Remember that any information you voluntarily disclose online in any news or message postings, discussion groups or chat rooms may be collected and used by others without your permission. Furthermore, if you provide any information to parties who operate websites that are linked to or from one or more of our websites, different policies may apply to their collection, use or disclosure of your personal information. We encourage you to review these external sites’ policies carefully before revealing any sensitive or personal information.

Regardless of the precautions taken by you or by us, “perfect security” does not exist on the Internet. We cannot ensure or warrant the security of any information you transmit to us, and you transmit such information at your own risk.

Is there an age restriction to use the site?

Federal law restricts our ability to collect information from children under a certain age online. For this and other reasons, InvestorsObserver’s websites are open only to persons 18 years of age and over. If we learn that a Member is under age 18, his or her access to InvestorsObserver will be immediately terminated with no further obligation to/from InvestorsObserver, and all identifiable information will be deleted.

Do you have an Auto-Trading feature?

Our service offers an auto-trade feature with certain brokers where trade ideas are sent directly to a subscriber’s broker. We do not in any way determine the investor’s fitness for the trades, which is the responsibility of the investor and his or her financial advisor or broker. Any auto-trade arrangement is purely between the investor and their broker. In order to verify that the member is eligible for use of our auto-trading services, the Member gives InvestorsObserver permission to verify account name and email address with their broker.

USE OF THIS SITE SIGNIFIES YOUR AGREEMENT TO THE PRIVACY POLICY AND TERMS OF SERVICE AGREEMENT.

How will I know if this privacy policy changes?

InvestorsObserver/O2 Media LLC reserves the right to modify this policy at any time.  If this policy changes, we will post the revised privacy policy on this web page. You can tell if this policy has changed by checking the Effective Date at the top and version number that appears at the end of this policy.

Version: 1