Itrust Investments

 At Itrust, we take privacy and security seriously. This Privacy Policy outlines how Itrust Financial LLC and its affiliates (collectively, the “Company,” “Itrust,” “we,” “our,” or “us”) process the information we collect about you through our websites, mobile apps, and other online services (collectively, the “Services”) and when you otherwise interact with us, such as through our customer service channels.

If you are a United State resident, please also see the “Notice to United State Residents” section below. If you have a Itrust account, or have taken steps to register for an account, you can also review our Consumer Privacy Notice for a summary of our practices regarding the information we collect about you.

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TYPES OF INFORMATION COLLECTED AND HOW WE COLLECT THEM  
HOW WE USE YOUR INFORMATION  
DISCLOSURES OF PERSONAL INFORMATION  
THIRD-PARTY LINKS  
THIRD-PARTY TRACKING AND ONLINE ADVERTISING  
CONTROL OVER YOUR INFORMATION  
NOTICE TO US RESIDENTS  
TRANSFER OF PERSONAL INFORMATION  
CHILDREN’S PRIVACY  
CHANGES TO THIS POLICY  
HOW TO CONTACT US

1. TYPES OF INFORMATION COLLECTED AND HOW WE COLLECT THEM.

Personal Information You Provide:

We collect the following personal information you provide when you use our Services, like when you sign up for an account, request a transaction, enrol in a promotion or program, or otherwise engage or communicate with us:

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Identity Data includes your full name, date of birth, gender, identity numbers, and  other data on government-issued identification documents.  
Contact Data includes your email address, mailing address, and telephone numbers.  
Financial Data includes your bank account and payment card details, suitability information, and information about your income, account balances, financial transaction history, credit history, tax information, and credit scores.  
Profile Data includes your username and password, purchases or orders made by you, your knowledge assessment results, and your interests, preferences, feedback, and survey responses.  
Usage Information includes information about how you access and use our Services, such as your actions on the Services, including your interactions with others on the Services, photos or media you upload to the Services, your username, and other content you provide (“Usage Information”). We only access your device camera roll and camera with your permission. If you need to update your permissions, you can do so in your device’s settings. Please remember that Itrust may, but has no obligation to, monitor, record, and store Usage Information to protect your safety or the safety of other users, to assist with regulatory or law enforcement efforts, to protect and defend our rights and property, or for other reasons relating to our provision of the Services. By using the Services, you consent to the recording, storage, and disclosure of such information you send or receive for these purposes.
Contact List Information With your permission, we may access your contact list on your mobile device or in your email accounts so that you can identify your contacts on the Services and direct the invitation of your contacts. We store and use this information to suggest referrals or connections and for other reasons related to our provision of the Services. We make these recommendations based on your contact list information as well as, with their consent, your contacts’ information if they are also a Itrust customer. We only access your contact list information with your explicit permission. If you provide us with personal data from your third-party contacts, it is your responsibility to ensure that the communication of such data to, and further processing by, Itrust is lawful. For example, when you provide us with information about your contacts, we may use it to let you know which of your contacts have also signed up for our Services or, at your exclusive direction, send messages to your contacts regarding our Services. We will not send messages to your contacts that are not explicitly directed by you.  
Additional Information: includes information that you submit via focus groups, contests/sweepstakes, job applications, customer support, or other similar means. We may also collect any communications between Itrust and you (including recording calls made to or by Itrust) and any other information you provide to Itrust.   
Personal Information Collected Automatically: As is true of many digital platforms, we collect certain personal information automatically when you visit our online services, including:
- Location Data:  To help us protect against fraud, provide our services to you, and improve our services, we collect location data, including current and historical information concerning a user’s geographic location, GPS location, transaction location, and IP addresses that they use in conjunction with our Services. We collect your precise location data with your permission, and use that information, for example, to help protect against fraud by detecting and declining debit card transactions that may occur far away from your device’s location. We collect information about your location through GPS, Wi-Fi, wireless network triangulation, or other methods to obtain your location. We may also approximate your location by your IP Address. We also use the Google Maps API to gather information about your location. Google uses various technologies to determine your location, including IP address, GPS, and other sensors that may, for example, provide Google with information on nearby devices, Wi-Fi access points, and cell towers (see Google’s Privacy Policy to learn more).  
- Usage and Device Data Collected Automatically Through Tracking Technologies:  To provide a personalized and enhanced user experience, we, and our third-party partners, automatically collect certain types of usage information when you visit or use our Services, read our emails, or otherwise engage with us. We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, embedded scripts, location identifying technologies, file information, and similar technology (collectively, “Tracking Technologies”). For example, we collect information about your device and its software, such as your IP address, browser type, Internet service provider, platform type, device type, operating system, date and time stamp, a unique ID (that allows us to uniquely identify your browser, mobile device, or your account), and other similar information. We use Tracking Technologies to help ensure that you have a high-quality experience on our Services. We also use Tracking Technologies to aid in the targeted advertising of our services on other platforms. From your device manufacturer, we also may collect the names of other third-party applications that you have downloaded on your device.  If you prefer, you can change your cookie settings. Some browsers have options that allow the user to control whether the browser will accept cookies, reject cookies, or notify the user each time a cookie is sent. You may elect to reject cookies by adjusting your settings but doing so will limit the range of features available to you on our Services and other websites. Be sure to read any information provided by your browser developer to understand the limitations of these settings, as they may differ from browser to browser and may not apply to all technologies. You may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email, used our Services, or performed certain functions with it.
- Our Services also occasionally use “local shared objects” (also known as “Flash cookies”). Like browser cookies, Flash cookies may be used for coordinating content delivery, website functionality, maintaining preferences, advertising, or analytics. Unlike browser cookies, “Flash cookies” are not stored in the browser. You may be able to manage these Flash cookies by visiting the Adobe website here.
- Do-Not-Track Signals and Similar Mechanisms. Some web browsers transmit “do-not-track” signals to websites. We currently don’t take action in response to these signals.

Personal Information You Provide:

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HOW TO CONTACT US

Acceptance of Terms and Conditions

By using the Service and the Content, you agree to follow and be bound by these Terms and Conditions, including the policies referenced herein. Customers of Itrust are granted additional levels of access to the website and their relationship with Itrust is governed by additional agreements and terms of use, such as the Customer Agreement.

Disclaimer and Limitations of Liability

The Content and the Service are provided on an “as is” and “as available” basis. To the fullest extent permitted under applicable law, Itrust and the Third Party Providers expressly disclaim all warranties of any kind with respect to the Content and the Service, whether express or implied, including, but not limited to, the implied warranties of merchantability, fitness for a particular purpose and non-infringement. Neither Itrust nor Third Party Providers guarantee the accuracy, timeliness, completeness or usefulness of any Content. You agree to use the Content and the Service only at your own risk. Neither Itrust nor the Third Party Providers explicitly or implicitly endorse or approve any Third Party Content. Third Party Content is provided for informational purposes only.

The Content is not intended to provide financial, legal, tax or investment advice or recommendations. You are solely responsible for determining whether any investment, investment strategy or related transaction is appropriate for you based on your personal investment objectives, financial circumstances and risk tolerance. You should consult your legal or tax professional regarding your specific situation.

ITRUST AND THE THIRD PARTY PROVIDERS WILL NOT BE LIABLE FOR ANY DIRECT, INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR EXEMPLARY DAMAGES, INCLUDING, BUT NOT LIMITED TO, DAMAGES FOR LOSS OF PROFITS, REVENUE, INCOME, GOODWILL, USE, DATA OR OTHER INTANGIBLE LOSSES (EVEN IF ITRUST OR ANY THIRD PARTY PROVIDER HAS BEEN ADVISED OF THE POSSIBILITY OF SUCH DAMAGES), RESULTING FROM: (1) THE USE OF OR THE INABILITY TO USE THE CONTENT OR THE SERVICE; (2) THE COST OF PROCUREMENT OF SUBSTITUTE GOODS AND SERVICES RESULTING FROM ANY GOODS, DATA, INFORMATION OR SERVICES PURCHASED OR OBTAINED OR MESSAGES RECEIVED OR TRANSACTIONS ENTERED INTO, THROUGH OR FROM THE SERVICE; (3) ACCESS TO OR ALTERATION OF YOUR ACCOUNT, TRANSMISSIONS OR DATA DUE TO YOUR CONDUCT, INACTION OR NEGLIGENCE; OR (4) ANY OTHER MATTER RELATING TO THE CONTENT OR THE SERVICE.

No Recommendations or Investment Advice

Itrust Investment provides self-directed investors with discount brokerage services, and does not make recommendations or offer investment advice of any kind. You are solely responsible for evaluating the merits and risks associated with the use of any Content provided through the Service before making any decisions based on such Content. You agree not to hold Itrust or any Third-Party Provider liable for any possible claim for damages arising from any decision you make based on the Content or other information made available to you through the Service or any Third-Party Provider websites. Past performance data should not be construed as indicative of future results.

Content

Content posted on the Service is published as of its stated date or, if no date is stated, the date of first posting. Neither Itrust nor the Third-Party Providers have undertaken any duty to update any such information. Itrust does not prepare, edit, or endorse Third Party Content. Itrust does not guarantee the accuracy, timeliness, completeness or usefulness of Third Party Content, and is not responsible or liable for any content, advertising, products, or other materials on or available from third party sites. You will not hold Itrust and/or any Third-Party Provider liable in any way for (a) any inaccuracy of, error or delay in, or omission of the Content; or (b) any loss or damage arising from or occasioned by i) any error or delay in the transmission of such Content; ii) interruption in any such Content due either to any negligent act or omission by any party to any “force majeure” (e.g., flood, extraordinary weather conditions, earthquake or other act of God, fire, war, insurrection, riot, labor dispute, accident, action of government, communications or power failure, equipment or software malfunction), or iii) to any other cause beyond the reasonable control of Itrust and/or Third-Party Provider, or iv) non-performance.  Any price quotes may be delayed 20 minutes or longer, according to the rules and regulations applicable to exchanges and Third Party Providers. Neither Itrust nor the Third-Party Providers make any representations, warranties or other guarantees as to the accuracy or timeliness of any price quotes. Neither Itrust nor the Third-Party Providers make any representations, warranties or other guarantees as to the present or future value or suitability of any sale, trade or other transaction involving any particular security or any other investment.

Content is provided exclusively for personal and non-commercial access and use. No part of the Service or Content may be copied, reproduced, republished, uploaded, posted, publicly displayed, encoded, translated, transmitted or distributed in any way (including “mirroring”) to any other computer, server, web site or other medium for publication or distribution or for any commercial enterprise, without Itrust’s express prior written consent.

You acknowledge that Itrust is the sole owner of Itrust Marks and that other Marks are the property of their respective owners. You agree that you will not use any Marks for any purpose without the prior express written consent of the respective owners.

Termination; Modification

You agree that, without notice, Itrust may terminate these Terms and Conditions, or suspend your access to the Service or the Content, with or without cause at any time and effective immediately. These Terms and Conditions will terminate immediately without notice from Itrust if you, in Itrust’s sole discretion, fail to comply with any provision of these Terms and Conditions. Itrust shall not be liable to you or any third party for the termination or suspension of the Service or the Content, or any claims related to such termination or suspension.

Itrust and/or the Third-Party Providers may discontinue or modify the Content, or any portion thereof, at any time. You release and agree to indemnify and hold harmless Itrust, and the Third- Party Providers, for any loss or damages arising from or relating to such discontinuation or modification.

Communications

By using the Service or the Content, you consent to any form of recording and retention of any communication, information and data exchanged between you and Itrust or its representatives or agents.

All communications made at or through the Forums are public. Neither Itrust nor the Third-Party Providers screen, review, approve or endorse any Third Party Content available on or through the Forums. Reliance on any Third Party Content available on or through the Forums is at your own risk. When discussing a particular company, stock or security in the Forums, you agree to reveal any ownership interest in such company, stock or security. Without limitation, you agree not to do any of the following:

upload, post, transmit or otherwise make available any Content that is unlawful, harmful, threatening, abusive, harassing, tortuous, defamatory, vulgar, obscene, libelous, invasive of another's privacy (including, but not limited to, any address, email, phone number, or any other contact information without the written consent of the owner of such information), hateful, or racially, ethnically or otherwise objectionable;
harm minors in any way;
impersonate any person or entity, including, but not limited to, (i) a Itrust or Third-Party   Provider manager, employee, agent, or representative or (ii) forum leader, guide or host;  
falsely state or otherwise misrepresent your affiliation with any person or entity;  
forge headers or otherwise manipulate identifiers in order to disguise the origin of any material;
upload, post or otherwise transmit any material that you do not have a right to transmit under any  law or under contractual or fiduciary relationships (such as inside information, proprietary and  confidential information learned or disclosed as part of employment relationships or under nondisclosure agreements);
upload, post or otherwise transmit any material that infringes any patent, trademark, trade secret,  copyright, rights of privacy or publicity, or other proprietary rights of any party;
upload, post, or transmit unsolicited commercial email or “SPAM,” including, but not limited to,   unethical marketing, advertising, or any other practice that is in any way connected with SPAM, such as: (1) sending mass email to recipients who haven't requested email from you or with a fake return address; (2) promoting a site with inappropriate links, titles, or descriptions; or (3) promoting any site by posting multiple submissions in forums that are identical;
upload, post or otherwise transmit any material that contains software viruses or any other computer code, files or programs designed to interrupt, destroy or limit the functionality of any computer software or hardware or telecommunications equipment;  
interfere with or disrupt the Service or servers or networks connected to the Service, or disobey any requirements, procedures, policies or regulations of networks connected to the Service;  
intentionally or unintentionally violate any applicable local, state, national or international law,   including, but not limited to, regulations promulgated by the U.S. Securities and Exchange Commission, any rules of any national or other securities exchange, and any regulations having the force of law;
“stalk” or otherwise harass another;
collect or store personal data about other users of the Service;  
collect or store personal data about other users of the Service;  
promote or provide instructional information about illegal activities, promote physical harm or   injury against any group or individual, or promote any act of cruelty;  
promote, offer for sale or sell any security or item, good or service that i) violates any applicable  federal, state, or local law or regulation, ii) you do not have full power and authority under all relevant laws and regulations to offer and sell, including all necessary licenses and authorizations, or iii) Itrust or the Third-Party Providers determine, in their sole discretion, is inappropriate for sale;
use the Forums as a forwarding service to another website; or  
access or otherwise use the Forums in any unlawful manner, for any unlawful purpose or in   violation of these Terms and Conditions.

External Links

Itrust and/or the Third-Party Providers may provide links to other websites or resources. Because neither Itrust or the Third-Party Providers have any control over such sites and resources, you acknowledge and agree that neither Itrust nor the Third Party Providers are responsible for the availability of such external sites or resources. Itrust and the Third Party Providers do not endorse and are not liable for any content, advertising, products, or other materials on or available through such sites or resources. You further acknowledge and agree that neither Itrust nor the Third Party Providers shall be responsible or liable, directly or indirectly, for any damage or loss caused or alleged to be caused by or in connection with use of or reliance on any such content, goods or services available on or through any such site or resource.

Applicable Policies

In addition to these Terms and Conditions, your access to and use of the Content and the Service is subject to Itrust’s then-current policies relating to the Content and the Service, including, without limitation, the Itrust Privacy Policy available on the Service. You agree to be bound by these policies and all other Itrust policies applicable to the access and use of the Content and the Service.

By using the Service, you are consenting to have your personal data transferred to and processed by Itrust and its affiliates. As part of providing you the Service, Itrust may need to provide you with certain communications, such as service announcements and administrative messages. These communications are considered part of the Service, which you may not be able to opt-out from receiving.

Indemnification

You will indemnify and hold harmless Itrust and the Third Party Providers, and the officers, directors, agents, partners, employees, licensors, distributors, and representatives of Itrust and the Third Party Providers, from and against any and all claims, demands, actions, causes of action, suits, proceedings, losses, damages, costs, and expenses, including reasonable attorneys' fees, arising from or relating to your access and/or use of, or interaction with the Content (including, without limitation, Third Party Content), or any act, error, or omission of your use of your account or any user of your account, in connection therewith, including, but not limited to, matters relating to incorrect, incomplete, or misleading information; libel; invasion of privacy; infringement of a copyright, trade name, trademark, service mark, or other intellectual property; any defective product or any injury or damage to person or property caused by any products sold or otherwise distributed through or in connection with the Service; or violation of any applicable law.

Revisions

Itrust may at any time revise these Terms and Conditions by updating this document. You agree to be bound by subsequent revisions and agree to review these Terms and Conditions periodically for changes. The most updated version of this document will be available for your review under the “Itrust Terms and Conditions” link that appears on the Itrust website and mobile application.

Applicable Law and Venue; Severability

You agree that these Terms and Conditions shall be governed by and interpreted in accordance with the laws of the State of California, without giving effect to principles of conflicts of law. Any legal action or proceeding arising under these Terms and Conditions will be brought exclusively in courts located in Santa Clara County, California, and you hereby irrevocably consent to the personal jurisdiction and venue therein. If any provision of these Terms and Conditions is deemed unlawful, void or for any reason unenforceable, then that provision will be deemed severable from these Terms and Conditions and will not affect the validity and enforceability of the remaining provisions.