Privacy Policy

MICROQUANT d/b/a BASE CAMP TRADING

Privacy Policy

 

This Privacy Policy is effective as of March 23, 2022.

 

This Privacy Policy (“Policy”) describes the practices of MicroQuant, LLC d/b/a/ basecamptrading.com (“Base Camp Trading”, “we” or “our”), with respect to the information provided by, or collected from, visitors, trial members or members of this website (www.basecamptrading.com) and our blogs, webinars, videos, social media pages and all other services provided by Base Camp Trading (collectively, the “Platform”), including information that is gathered from correspondences (including email) from or about registrants or attendees at events, or through interactions with Base Camp Trading’s representatives (collectively “Services”). Such visitor(s), trial member(s), member(s), registrant(s), and attendee(s) are each referred to herein as a “user” or “you.”

 

This Privacy Policy provides information as to who we are, and how and why we collect, store, use, and share your Personal Data. It also explains your rights in relation to your Personal Data and how to contact us or supervisory authorities in the event you have a complaint. Base Camp Trading is the data controller regarding all Personal Data processing conducted through the Platform.

 

You acknowledge that this Privacy Policy is part of our Terms of Use, and by accessing or using our Platform, you agree to be bound by all of its terms and conditions. If you do not agree to these terms, please do not access or use all or any portion of the Platform.

 

1.       Contact Information

The data controller is:                      MicroQuant, LLC

                                                                  811 Sixth Street

                                                                  Suite 220

                                                                  Wichita Falls, TX 76301

                        

The EU Representative is:               Bourlux Limited

                                                                  1st Floor, 9 Exchange Place

                                                                  IFSC Dublin, Ireland 1

 

The Data Protection Officer is:      Brian Strong

                                                                  support@basecamptrading.com

 

2.       Categories of Personal Data Collected and Source of the Data 

Base Camp Trading collects information that a user chooses to provide by engaging in certain activities on the Platform, for example, by registering as a member, completing a form to download a white paper or request a document, ordering a product or service, submitting content, exchanging email or other correspondences with us or our representatives, and/or posting content in discussion forums or other public areas, entering a contest or sweepstakes, filling out a survey, or sending us feedback. We also collect information by analyzing a user’s behavior, predispositions, preferences, activity and usage on the Platform over time to create a profile about a user. In general, users may visit unrestricted portions of the Platform anonymously and may refuse to supply Personal Data, though such refusal may prevent users from accessing portions of the Platform or participating in certain Platform related activities.

 

For purposes of this Policy, “Personal Data” that we may collect and process through the Platform or in connection with the Services means personal information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household, including but not limited to:

 

Identifying Information: In various sections of the Platform (including to make a purchase and to access designated member services and/or restricted areas) users are asked to provide personal identifying information, such as: name, e-mail address, phone number, billing address, account name, organization, and/or other similar identifiers.

 

Payment Information: If a user requests Services (including registration to become a trial member or member) for which payment is required, the user may be asked to provide payment information such as: method of payment, credit card number, credit card security code or card verification code, credit card expiration date, and other information which may be necessary to process such transactions. This information is collected and processed by an external payment processor; it is not accessed or stored by Base Camp Trading. This Personal Data is required to provide products and/or Services to you. If you do not provide Personal Data we ask for, it may delay or prevent us from providing products and/or Services to you.

 

Member Information: If a user registers to become a trial member or member, we create an account in the name of that individual. To establish and maintain such a trial membership or membership we may request identifying information, payment information, and addition information necessary to establish or maintain your account. Only the minimum amount of information necessary to establish or maintain the account is mandatory. To access the user account, the registrant is required to choose a password.

 

Communication from Users: When a user completes an online form, visits our Platform, or otherwise contacts us by email, phone or text, we automatically collect and store certain information about that user and the user’s activities, such as: name and contact information, information the user provides us, user’s company information (if any), nature of the communication, purpose of the interaction, action taken by Base Camp Trading or user in response to the user’s  inquiry or request, and/or demographic information.

 

Communications to Users: Unless we are prohibited by applicable law from using cookies or a user has not otherwise consented to our use of cookies, we insert cookies in some of our correspondences which allow us to determine whether a user has accessed or declined to open our message and count other unique clicks or visits. This information helps us understand how the user reacts to our communications.

 

Surveys and Contests: From time-to-time, we invite users to participate in surveys or contests. Participation is voluntary. When a user participates, we collect and store your responses to such surveys, contests, and promotions. Depending on the nature of the survey or contents, we also use this information to send the survey results to the participants, or, if applicable, to notify contest winners and award prizes. We also use the information in aggregate form, for analytics purposes, to understand our market, to monitor site traffic or app usage, or to modify our Platform or our Service to meet the needs or interests of users.

 

If we use a third-party service provider to conduct these surveys, the information collected by the service provider is subject to both the service provider’s privacy policy and ours. We will provide information about the applicable privacy policies with the survey rules and will seek your explicit consent to these rules when required by law. You should read the terms of the survey or contest to understand the extent to which the service provider is allowed to use or reuse the information collected.

 

Social Media: Our Platform offers integrations with third-party social media platforms. These services collect, at a minimum, the user’s IP address and which page of our Platform the user is visiting. They may set a cookie to enable their features to function properly. Social media features and widgets are hosted by a third party or directly on our Platform. Your interactions with these features are governed by the privacy policy of the company providing the feature.

 

Publicly Available Data: We collect information available from publicly accessible sources, such as property records or information about a user’s interests.

 

Information Provided by Users: Certain areas of the Platform allow you to write messages to other users or post content, which such messages or posts may contain Personal Data. You should be aware that information so disclosed or shared will be generally available to other persons, both inside of and/or outside of the Platform, who have access to such areas of the Platform. All such information is disclosed or shared at a user’s own risk. All user opinions contained in such messages or posts do not reflect the opinions of Base Camp Trading. We request that you do not disclose:

  • Any data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, genetic data, biometric data or data concerning your health, sex life or sexual orientation.
  • Any identifying data, including social security number, national identification number, financial account information or any other sensitive or confidential information.
  • Any data (including identifying data) related to other persons.

 

Log Data: When a user uses or interacts with our Platform, or clicks on a link that directs the user to our Platform, the user’s browser automatically provides, and we automatically collect and store, certain information about the user’s device and the user’s activities, such as:

  • Preferences and settings:  Time zone, language, character size, etc.
  • Identifiers:  IP address.
  • Technical information: Device information, operating system and version, browser information, screen resolution, etc.
  • Coarse Geographic information: General geographic location derived from the IP address.

We collect this data for the proper operation of our Platform. Until the user registers with us, this data cannot be linked to a specific individual.

 

Traffic Data: Data generated through a user’s use of the Platform, such as: pages viewed, time spent per page, data of page visit(s), URL of the last webpage visited before visiting a page of our Platform, click through and clickstream data, search history, search results selected; comments made, type of service requested, purchases made.

 

3.          Purposes of Processing Personal Data 

Under data protection law (including the European Union General Data Protection Regulation (“GDPR”)), we can only use your Personal Data if we have a proper reason for doing so. We use Personal Data for the following purposes:

 

Service

·   To provide products and Services to users and to perform our obligations under any contract with you;

·   To take steps at your request before entering into a contractual relationship with a user;

·   To allow members to create and maintain their account, verify the member’s identity and assist a user in the event of lost or forgotten login or password;

·   To respond to user inquiries, allow users to sign up for newsletters, and request white papers or other information;

·   For interaction on social media; and

·   To develop new products and services features.

 

Marketing

·   To provide marketing information regarding Base Camp Trading’s products and Services, or those of selected third parties (as allowable by applicable law) to potential and existing users and/or members;

·   To understand our market and promote our business, including through market research and surveys;

·   To provide information in which a user has indicated an interest; and

·   To send marketing communications regarding products and services that are identical or similar to those a user has previously purchased or requested via the Platform.

 

Profiling

·   To create a profile of a person as a Platform user (including through the use of profiling cookies) in order to provide information, advertisements and offerings of Services relevant to that user.

 

Operational Reasons

·   To develop and administer the Platform;

·   To improve Base Camp Trading’s offerings and Services;

·   To enhance user’s(s’) experience;

·   To troubleshoot any technical issues; and

·   To be as efficient as we can to deliver the best Services and information to you.

 

Misuse or Fraud

·   To prevent and detect any fraud against you or Base Camp Trading, misuse of the Platform, or any fraudulent or criminal activities carried out through the Platform;

·   To verify the identity of our customer, members and users;

·   To ensure the confidentiality of commercially sensitive information;

·   Preventing unauthorized access and modifications to systems; and

·   To ensure our business policies are adhered to.

 

Compliance with Legal and Regulatory Obligations

·   Gathering and providing information required by or relating to audits, enquiries or investigations by regulatory bodies;

·   To ensure safe working practices, staff administration and assessments;

·   To perform/comply with external audits and quality checks; and

·   Other processing necessary to comply with professional, legal and regulatory obligations that apply to our business.

 

4.       Marketing and Promotional Considerations

We may use your Personal Data to send you updates (by email, text message, telephone or post) about our products and Services, including exclusive offers, promotions or new products and/or Services.

 

We have a legitimate interest in processing your Personal Data for promotional purposes (see above “Purposes of Processing”). This means we do not usually need your consent to send you promotional communications. However, where consent is needed, we will ask for this consent separately and clearly.

 

You have the right to opt out of receiving promotional communications at any time by:

Contacting us at support@basecamptrading.com;

Using the “unsubscribe” link in emails or “STOP” number in texts; or

Updating your marketing preferences in your member or trial member account settings.

We may ask you to confirm or update your marketing preferences if you request further products and/or Services in the future, or if there are changes in the law, regulation, or the structure of our business.

 

5.       Recipients of Personal Data 

We use our best efforts to only share your Personal Data fairly, lawfully, and proportionately in light of the legitimate interests and needs of our business, our legal obligations, and our obligations under our contracts. Our practices are intended to address each individual’s legitimate rights and expectations in view of the context and purpose of the collection and use of the information collected; without being intrusive or contrary to individuals’ rights. If you would like more information about who we share our data with and why, please contact us (see "How to Contact Us" below). In light of the foregoing, we share Personal Data with:

 

Marketing Partners

In countries where such activities do not require prior explicit consent of a user, we provide Personal Data to third party marketing companies, advertising agencies, and data aggregation companies. These third parties use such Personal Data to provide individuals with information on products and services of interest. In countries, such as in the EEA, where such activities are restricted, we conduct these activities in accordance with applicable local laws.

 

Service Providers

We share information with our suppliers, subcontractors, and other third parties who provide services to us to help use run our business (such as hosting services, data analytics providers, insurers, our banks, external auditors, and information technology providers), to help us deliver our products and Services to you (such as payment service providers, warehouses, order fulfillment, delivery (physically or digitally) companies, and related activities necessary to provide the products or perform the Services, and as necessary to comply with our legal or contractual obligations. We provide only the information such service providers need to perform their designated functions. Our contracts with them prohibit them from using or sharing with others the information that we provide to them.

 

Affiliated Entities

We share information with our affiliates (i.e., entities that are under common ownership or control of Base Camp Trading). Subject to local law requirements, express preferences indicated by individuals, or our contractual obligations, this information is used to promote services offered by our affiliates and for the purposes described in this Privacy Policy.

 

Third Parties Approved by Users

We share Personal Data with third parties approved by you, including social media sites you choose to link to your account to or third-party payment providers.

 

Law Enforcement; Fraud Prevention; and Protection of Legal Rights

We use and disclose information to the appropriate credit reporting, legal, judicial or law enforcement authorities and our advisors and investigators (i) when we believe, in our sole discretion, that such disclosure is necessary to comply with our legal and regulatory obligations; to investigate, prevent, or respond to suspected illegal or fraudulent activity; or to protect the safety, rights, or property of Base Camp Trading, its customers, members, trial members, visitors, users, or others; (ii) Data if a court, law enforcement or other public or government authority with appropriate jurisdiction so requests, and we believe, in our reasonable discretion, that such request was made in compliance with applicable law; (iii) when an individual has abused the Platform and/or Services, exceeded the permitted use of the Platform and/or Services, gained unauthorized access to the Platform and/or any Services, engaged in spamming, denial of service attacks, use of malicious code, or similar attacks; (iv) to exercise or protect legal rights or defend against legal claims; or (v) to allow us to pursue available remedies or limit the damages that we sustain.

 

Corporate Reorganization

We transfer Personal Data to a third party in case of the reorganization, sale, merger, joint venture, assignment, transfer or other disposition of all or any portion of our business, asset or stocks, including in the event of bankruptcy or corporate restructuring. Except as otherwise provided by a bankruptcy or other court, the use and disclosure of all transferred Personal Data will be subject to policies that are consistent with the policies described in this Privacy Policy. Any information that any individual submits or that is collected after that transfer is subject to a new privacy policy adopted by the successor entity.

 

6.       Personal Date We Sold or Disclosed for a Business Purpose

We have not sold to a third party any Personal Data that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

 

However, in the preceding 12 months, we have disclosed for a business purpose to one or more third parties the following categories of Personal Data:

·   Identifiers (e.g., a real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers).

·   Information that identifies, relates to, describes, or is capable of being associated with, a particular individual, including, but not limited to, name, signature, social security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information;

·   Characteristics of protected classifications under California or federal law;

·   Commercial information (e.g., records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies);

·   Biometric information;

·   Internet or other electronic network activity information (e.g., browsing history, search history, and information regarding a consumer’s interaction with an Internet Web site, application, or advertisement);

·   Geolocation data;

·   Audio, electronic, visual, thermal, olfactory, or similar information;

·   Professional or employment-related information;

·   Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (FERPA); and

·   Inferences drawn from any of the information identified above to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

7.       Retention of Personal Data 

Personal Data may be held at our offices and those of our third-party agencies, services providers, and representative as described above (see above, “Recipients of Personal Data”). Generally, we retain Personal Data we collect from you as long as we have an ongoing legitimate business need to do so, including:

·   To provide you with a product or Service you have requested;

·   As necessary to fulfill our contractual obligations;

·   To maintain your accounts and memberships with us;

·   To comply with legal, tax or accounting requirements and maintain records as required by law;

·   To respond to questions and complaints made by your or on your behalf;

·   To resolve disputes; and

·   To enforce our agreements.

We will not retain your Personal Data for longer than necessary for the purposes set out in this Policy. We will delete, anonymize or otherwise discard user data (including Personal Data and all other data) we collect about you while using our Platform when it is no longer necessary to retain such information or when you contact us to do so. You can initiate such a request by contacting our customer service department (see below, “How to Contact Us”).

8.       Cookies

In some countries, the law requires us to provide you with detailed information about the cookies that are stored on your device when you access, visit or otherwise use our Platform or Service(s). The law also requires that we obtain your consent to the use of certain types of cookies. This cookie policy aims to provide you with information about cookies, how we use them, and when applicable law how we request your consent.

 

What are “cookies”?

Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. They are used for numerous different purposes, including to remember a user’s actions and preferences (for example, login data, language, font size, other display settings, etc.), so that the user does not have to configure them again when visiting the Platform, or when moving from page to page within a website.  Some operations within a website will not be able to be performed without the use of cookies which, in certain cases, are technically necessary for operation of the website. They also contain a unique ID code that allows tracking a user’s browsing activities within a website, for statistical or advertising purposes.

 

Technical/Functional Cookies

For some types of cookies, the consent of the user is unnecessary. This is the case for “technical cookies” and “functional cookies” which are only used to send messages through an electronic communication network, are needed to provide the user with the service that the user requests, are used to allow the user to login, and are used to remember choices made by a user when accessing the Platform, such as language, fonts, settings, or to remember the products selected for purchase. These cookies are essential for the proper operation of the functions offered by the Platform.

 

Cookies present on the Platform

We use the following types of cookies:

   Browsing or session cookies: We use browsing or session cookies as necessary for the operation of the Platform, and/or to allow the user to access and use the content of the Platform and the Services.

   Analytics cookies: We use Google Analytics to collect information that permits evaluation of the use of the Platform, and analysis of user’s behavior and improvement of user experience. Information about how to opt out of being tracked by Google Analytics is available at: https://tools.google.com/dlpage/gaoptout.

   Technical/Functional cookies: We use functional cookies to activate specific functions and to configure webpages according to the user’s preference such as font size or language.

   Profiling cookies:  We use profiling cookies to observe a user’s interest based on activities on a website, and to send advertisements that take these preferences into account. You may opt-out of being tracked by these cookies

   Third party cookies: We use third party cookies, owned by third parties to allow the collection of information about you so that we can send advertisements to you when you visit other websites. You may opt-out of being tracked by these cookies. Please notes that opting out of receiving interest-based advertising does not block all advertisements served to your device. You will continue receiving advertisements, but these advertisements will be generic or based on the content of a webpage that you are visiting, instead of being targeted to your specific interests.

Users Located in the EEA

Pursuant to the EU Cookie Law and the GDPR, we can store cookies on your device that are essential to the operation of the Platform, such as functional cookies. For all other, non-essential types of cookies, we need prior consent from users located in the EEA.

 

How we Obtain your Consent (for users in the EEA)

The first time you visit our Platform or at any other time after you have deleted our cookies from your device, you will be presented with a notice informing you that the Platform uses cookies. We will only use non-essential cookies if you express your consent by clicking on the appropriate box. If you decide to continue through our Platform after being presented with that notice, without clicking on the appropriate box, we will assume that we do not have your consent to set cookies as described in this policy.


Disabling or blocking cookies

You can block our Platform from setting cookies and can delete cookies at any time by modifying the settings of your browser. Please review the “Help” section of your browser.

 

CAUTION:  If you block or delete technical and/or functional cookies used by the Platform, the Platform may become impossible to browse, certain services or functions of the Platform may become unavailable or other malfunctions may occur.

 

9.       Security

We use commercially reasonable technical, organizational, physical, managerial, and administrative safeguards to protect information within our control against unauthorized or unlawful access, use, modification, destruction, processing or disclosure, and against accidental loss, destruction, or damage. We limit access to our users’ Personal Data to only those who have a genuine business need to access it. Those processing your information will do so only in an authorized manner and are subject to a duty of confidentiality.

 

Please be aware, however, that no data security measures can be guaranteed to be completely effective. Consequently, Base Camp Trading cannot ensure or warrant the security of collected data or other information. In particular, we cannot guarantee that collected data or other information will not be disclosed, altered, or accessed in accidental circumstances or by unauthorized or unlawful acts of others.

 

We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

 

If you have reason to believe that the security of your account or Personal Data might have been compromised, if you suspect someone else is using your account, or if your credit, bank, other financial institution information, username or password is lost, stolen or used without permission, contact us immediately as indicated in the “How to Contact Us” section.

 

10.  Transfers of Personal Data

Base Camp Trading operates its technology from servers located in the United States and the information it collects through clients is processed solely in the United States. Laws governing the collection and use of data in the EEA or United States may not be equivalent to those in the country where you reside, but we will at all times protect your data in accordance with this Policy.

 

We may share your information with our affiliates and other third parties described above who are based in countries outside of your country of residence. In such circumstances, we will take all reasonable measures to protect your information in accordance with this Privacy Policy and all applicable legal requirements.

 

If any of the recipients is located in a country without the adequate legal protection or safeguards for Personal Data, Company will make reasonable efforts to cause the recipient adopts the principles described in this Privacy Policy.

 

11.   Rights of Individuals Located in the European Economic Area 

The GDPR grants individuals who are in the EEA the following rights, with some limitations. Users may contact us, at the address provided in the “How to Contact us” section below, to exercise any of those rights and we will respond with the requested action or information or will let you know why that right does not apply to you.

 

Right of Access: You have the right to request a copy of your Personal Data. We may charge you a small fee for this service.

 

Right of Rectification: You have the right to request that we correct any Personal Data you believe is inaccurate, and that we complete Personal Date you believe is incomplete. 

 

Right of Erasure: In certain circumstances, you have the right to request that we erase your Personal Data; for example, if it is no longer necessary for the purposes for which it was originally collected.

 

Right to Restrict Processing: In certain circumstances, you have the right to request that we restrict the processing of your Personal Data; for example, where you believe that such Personal Data is inaccurate.

 

Right to Data Portability: In certain circumstances, you have the right to request that we transfer your Personal Data that we have collected to you or to another organization in a structured, commonly used, machine readable format.

 

Right to Object to the Processing: You have the right to object:

   At any time to your Personal Data being processed for direct marketing and/or profiling; and

   In certain circumstances, to our continued processing of your Personal Data.

Right Not to be Subject to Automated Individual Decision-Making: In certain circumstances, you have the right not to be subject to a decision based solely on automated processing - including profiling - that produces legal effects or similarly affects you.

  

12.   Rights of Users Who Are California Residents

The California Consumer Privacy Act (“CCPA”) and other applicable California state privacy laws provide California residents with specific rights regarding their Personal Data free of charge, including the following:

 

Right to Know Personal Data We Collect About You: You have the right to request that we disclose certain information to you about our collection and use of your Personal Data over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

   The categories of Personal Data collected about you.

   The categories of sources from which we collected Personal Data about you.

   Our business or commercial purpose for collecting, using or selling your Personal Data.

   The categories of third parties with whom we share such Personal Data.

   The specific pieces of Personal Data we have collected about you.

   If we sold or disclosed your Personal Data for a business purpose, two separate lists disclosing:

o  Categories of Personal Data about you that we sold, and the categories of third parties to whom the Personal Data was sold; and

o  Categories of Personal Data we disclosed about you for a business purpose.

 Please note that we are not required to:

   Retain any of your Personal Data that was collected for a single one-time transaction if, in the ordinary course of business, that information about you is not retained;

   Reidentify or otherwise link any data that, in the ordinary course of business, is not maintained in a manner that would be considered Personal Data; or

   Provide your Personal Data to you more than twice in a 12-month period.

Right to Opt-Out of the Sale of Personal Data: If you are a California resident, you have the right under the CCPA and certain other privacy and data protection laws, as applicable, to opt-out of the sale of your Personal Data. If you exercise your right to opt-out of the sale of your Personal Data, we will refrain from selling your Personal Data, unless you subsequently provide express authorization for the sale of your Personal Data. To opt-out of the sale of your Personal Data, send an email with the request to support@basecamptrading.com.

Right to Deletion: You have the right to request that we delete any of your Personal Data that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Data from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

·   Complete the transaction for which we collected the Personal Data, provide a good or Service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you;

·   Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities;

·   Debug to identify and repair errors that impair existing intended functionality;

·   Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law;

·   Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

·   Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when our deletion of the information is likely to render impossible or seriously impair the research’s achievement, if you previously provided informed consent;

·   Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us;

·   Comply with a legal obligation; or

·   Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Right to Non-Discrimination: You have the right to not be discriminated against by us because you exercised any of your rights under the CCPA. This means we cannot, unless permitted by the CCPA, among other things:

·   Deny goods or services to you;

·   Charge different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties;

·   Provide a different level or quality of goods or services to you; or

·   Suggest that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

Please note that we may charge a different price or rate or provide a different level or quality of goods and/or Services to you, if that difference is reasonably related to the value provided to our business by your Personal Data.

 

Shine the Light

Under California law, a business that has an established business relationship with an individual, and has, within the immediately preceding calendar year, disclosed Personal Data that is primarily used for personal, family or household purposes to third party for the third party’s direct marketing purposes, must disclose to its California users, upon request, the identity of any such third party, along with the type of Personal Data disclosed. You can contact us as provided in the “How to Contact Us” section to obtain such information. Please note that under California law, businesses are only required to respond to a user’s request once during any calendar year.

 

Do-Not-Track

Since there is no widely accepted standard for “Do Not Track” signals, we have not yet developed features that would recognize or respond to browser initiated Do Not Track signals.

 

13.   How to Exercise Your Rights

To exercise any of your rights as described in this Policy, please email or write to us at the email address and address listed in the “How to Contact Us” section below. Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Data. You may only make a verifiable consumer request for access or deletion once within a 12-month period. The verifiable consumer request must:

   Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Data information or an authorized representative.

   Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

   Include your full name, email address and phone number so we may process your request in an efficient manner.

Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to Personal Data associated with that specific account. We are not obligated to make a data access or data portability disclosure if we cannot verify that the person making the request is the person about whom we collected information or is someone authorized to act on such person’s behalf.

 

We will only use Personal Data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

 

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

 

14.   How to File a GDPR Complaint

We hope that we or our Data Protection Officer can resolve any query or concern you raise about our use of your information. The GDPR also gives you right to lodge a complaint with a supervisory authority in the EEA state where you work, normally live, or where any alleged infringement of data protection laws occurred.

 

15.   Children’s Privacy

Our Platform is not directed to individuals under the age of 18. We do not solicit or knowingly collect Personal Data from such individuals. If you become aware that a child has provided us with Personal Data, please contact us as indicated in the “How to Contact Us” section below. If we obtain actual knowledge that we have collected Personal Data from a child under the age of 18, we will take steps to delete such information from our database.

 

16.   Amendments 

We may revise this Privacy Policy at any time. Such changes, modifications, additions or deletions shall be effective immediately upon notice thereof. We may provide notice of any material change to this Privacy Policy directly on this page, by prominently displaying notice of changes on our homepage, and/or by sending an email to the email address listed by registered users. We encourage you to visit this page periodically to review our current privacy policy so that you will always know what information we gather and how we may use that information. Your continued use of the site after such modifications will constitute your: (a) acknowledgment of the modified Policy; and (b) agreement to abide and be bound by the modified Policy.

 

17.   How to Contact Us 

We are committed to resolving questions and complaints about our collection or use of your Personal Data. Inquires or complaints regarding this Privacy Policy should contact Base Camp Trading at:

 

                support@basecamptrading.com

 

                OR

 

                811 Sixth Street, Suite 220

                Wichita Falls, TX 76301.

 

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