MICROQUANT – BASE CAMP TRADING
- Contact Information
The data controller is: MicroQuant, LLC
811 Sixth Street
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
- Categories of Personal Data Collected and Source of the Data
The “Personal Data” that we collect and process through the Platform or in connection with the Services includes:
Name, contact details
In various sections of the Platform, users are asked to provide information about themselves, such as their name, e-mail address, phone number, billing address and organization. This happens, for example, when a user wishes to download a white paper or request to sign up for a newsletter.
If a user requests Services for which payment is required, the user is asked to provide payment information. This information is collected and processed by an external payment processor; it is not accessed or stored by BaseCampTrading.com.
Registered User Information
If a user registers to become a trial member or a member, we create an account in the name of that individual. Depending on the situations, we request:
- First and Last Name
- Email address
- Street address, including country
- Telephone number
- Credit Card Number, Card Security Code or Card Verification Code and Expiration Date
Only the minimum amount of information necessary to operate or manage 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 (for example on social media), or when a user otherwise contacts us, by email, phone or text, we automatically collect and store certain information about that user and the user’s activities, as we receive from such user, for example:
- The user’s name and contact information;
- Information that the user provides to us;
- The user’s company information, if any;
- The nature of the communication;
- The purpose of the interaction, and the action we took in response to the user’s inquiry or request;
- Any action the user takes upon receipt of such communication (for example, whether the user registers to attend an event that we offer, or request to receive documentation);
- Demographic information.
The information collected in connection with each type of interaction is retained so that we can continue interaction with the requestor with respect to our Platform or Services.
Communications to Users
In that case, when we send an email message to a user, our message contains images or links that when viewed or clicked, allow us to know whether the user has accessed or declined to open our message. This action also stores a cookie that allows us to count unique clicks or visits and potentially track the recipient.
This information helps us understand how the individual reacts to our communications and limit the amount and nature of information provided.
Surveys and Contests
From time-to-time, we invite users to participate in surveys or contests. Participation is voluntary. These surveys are organized for the purposes of our marketing efforts. When a user participates, we request certain personal data such as name and email address.
This is necessary to ensure that responses are categorized properly and are not duplicated. 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.
Publicly Available Data
We also collect information available from publicly available directories, and information that has been made available be an individual on public for a, such as information about a person’s interests.
Certain areas of the Platform include free text fields, where you can write messages to other users, or post content that contains Personal Data. We request that you do not disclose:
- Any data revealing your racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, genetic data, biometric data or data concerning your health, sex life or sexual orientation
- Any social security number, national Identification number, financial account information or any other information that might be deemed highly sensitive or confidential.
- Any data related to other persons.
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 (computer, tablet, smartphone) and the user’s activities. This includes:
- Preferences and settings: time zone, language, and character size.
- Identifiers: IP address.
- Technical information: type of device, operating system name and version, device manufacturer, browser information (type, version), screen resolution.
- Coarse Geographic information: 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.
Data generated by the use of the Platform also includes:
- Information about use of the Platform: date stamp, URL of the visited page, URL of the last webpage visited before visiting our Platform or a website using our Platform. URL of the last webpage visited before visiting our Platform.
- History of interaction with our webpages: pages viewed, time spent on a page, click through, clickstream data; queries made, search history, search results selected; comments made, type of service requested, purchases made. (for EEA users, if the user has accepted profiling cookie)
- Purposes of processing
We use Personal Data for the following purposes:
- To allow registered members to create and maintain their, verify the member’s identity and assist user if he/she misplaces or forgets his/her login or password;
- To respond to users’ inquiries, allow users to sign up for newsletters, request white papers, or other information, in order to contribute to or download BaseCampTrading.com white paper or content;
- To finalize purchase orders and deliver a Services to the user;
- To carry out market research and surveys;
- For interaction on social media; and
- To develop new products and services features.
- For marketing purposes via e-mail, text, phone, instant messaging, regarding BaseCampTrading.com’s products and services, or those of selected third parties, such as sponsors; (with limitations for users located in certain countries such as the EEA or Canada); and
- To interact with existing customers by sending marketing communications regarding products and services that are identical or similar to those the user has previously purchased or requested via the Platform.
- To create a profile of a person as a Platform user, through the use of profiling cookies and by collecting and analyzing information on the user’s interest in order to serve to each information and advertisements relevant to that user. All algorithms involved in this processing are regularly tested, to ensure the processing’s fairness and control for bias with limitations for users located in the EEA.
- For development and administration of the Platform, to improve BaseCampTrading.com’s offerings and troubleshoot any technical issues which arise in connection with the use of the Platform (“Analytics”), with limitations for users located in the EEA.
Misuse or Fraud
- To prevent and detect any misuse of the Platform, or any fraudulent activities carried out through the Platform (“Misuse/Fraud”).
- Legal Basis for the Processing
The European Union General Data Protection Regulation (“GDPR”) requires that we provide information to users located in the European Economic Area (“EEA”) about the legal ground for the processing of their data. This section applies only to users who are in the EEA.
The grounds on which we rely to process Personal Data, according to the purposes identified include the following:
The information necessary to provide the Services, fulfill the request that you make, take steps before entering into a contract with you, or perform a contract entered into with the user.
If you do not provide the information you need, we will not be able to provide certain Services to you over the Platform
The collection of information for marketing is needed for the legitimate interest of the BaseCampTrading.com so that it can understand its market and have opportunities to communicate with potential or current customers so long that the use of the data is no overridden by the interest of the individual.
Some forms of marketing to certain users require opt-in consent, and we will request such consent as applicable
Users have the right to object to the use of their personal data for marketing purposes.
There is no consequence for not providing the information.
A user who has previously consented to the use of personal data for marketing, can withdraw this consent at any time.
Marketing to Existing Customer
Marketing to existing customers is based on BaseCampTrading.com’s legitimate interest in expanding its relationship with individuals who have previously purchased or shown interest in goods or services provided by BaseCampTrading.com that are identical or similar to those the individual has previously purchased or requested through the Platform.
Users can opt-out of these communications at any time.
For some users, processing is based on the user’s consent, collected by means of the cookie pop-up banner and/or a specific tick box.
Users can elect to not consent to the collection of information about them through cookies.
There is no consequence for such refusal other than not being able to benefit from greater personalization when using the Platform.
BaseCampTrading.com has a legitimate interest in understanding how users use its Platform or Services, so that it can improve them accordingly both to enhance the user’s user experience, and to troubleshoot technical issues.
BaseCampTrading.com has a legitimate interest in preventing and detecting fraudulent activities or misuse of the Platform for potentially criminal purposes.
- Categories of Recipients
We believe that our practices below are fair, lawful, and proportional in light of the legitimate interests and needs of our business, our legal obligations, and our obligations under our contracts; that they fairly address each individual’s legitimate rights and expectations in view of the context and purpose of the collection and use of the information collected; and are not intrusive or contrary to individuals’ rights.
Except as described below, BaseCampTrading.com will not share or disclose personal data with or to third parties. We share Personal Data with the following entities:
Disclosure to Marketing Partners
In countries where such activities do not require prior explicit consent of a user, we provide personal information of individuals to third party marketing companies, affiliates, advertising agencies, and data aggregation companies. These partner firms use this information 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.
We share information with our suppliers, subcontractors, and other third parties who provide services to us (collectively “service providers”) in connection with hosting, data analytics, information technology and infrastructure, order fulfillment, email delivery, auditing, and other related activities as necessary to perform the Services that the Customer purchased and 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, or that they collect directly for purposes other than as directed by us.
Fraud Prevention and Protection of Legal Rights
We use and disclose information to the appropriate 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 investigate, prevent, or respond to suspected illegal or fraudulent activity or to protect the safety, rights, or property of BaseCampTrading.com, its customers, visitors, users, or others; (ii) when an individual has abused the Services, exceeded the permitted use of the Service, gained unauthorized access to any Services, engaged in spamming, denial of service attacks, use of malicious code, or similar attacks; (iii) to exercise or protect legal rights or defend against legal claims; or (iv) to allow us to pursue available remedies or limit the damages that we sustain.
We will disclose Personal 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.
- Retention of Personal Data
Generally, we retain personal information we collect from you as long as we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements, resolve disputes and enforce our agreements). We will delete or otherwise discard customer data or data we collect about you while using our services at our discretion or when you contact us to do so. You can initiate such a request by contacting our customer service department. Specifically, we retain each category of personal data as follows:
Providing the Service
Retained as necessary to fulfill our contractual obligations to provide such service.
We retain the data as necessary to protect BaseCampTrading.com’s from any potential liability.
Marketing and Profiling
Retained from the moment the user gives consent until consent is withdrawn.
If consent is withdrawn or not renewed, Personal Data will no longer be used for these purposes.
We retain the data as necessary to protect the BaseCampTrading.com’s from any potential liability.
Marketing to Customers
Retained from the time when we receive it in the context of purchases or requests made via the Platform until the user objects to this processing.
If a user objects to the processing, the Personal Data will no longer be used for these purposes.
We retain the data as necessary to protect BaseCampTrading.com’s from any potential liability..
Retained for the period required by the specific legal obligation or by the applicable law.
Retained as long as necessary to fulfil the purposes for which it was collected, unless the user objects to the processing and there are no other legal grounds justifying the retention of the information.
Retained as long as necessary to fulfil the purposes for which it was collected, unless the user objects to the processing and there are no other legal grounds justifying the retention of the information.
What are “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 Site
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
Users located in the EEA have the right to prohibit the use of certain cookies. Technical cookies such as cookies used to allow users to login, and functional cookies, such as those used to remember choices made by a user when accessing the Platform usually do not require prior consent.
However, cookies used to create profiles on users and to send advertising messages that take into account the preferences revealed by users while browsing websites usually require prior consent from users located in the EEA.
How we Obtain your Consent (for users in the EEA)
If the notice contains a request to agree to the use of our profiling cookies, we will use these 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 black our Platform or other sites 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. In this case, you may have to modify or manually enter some information or preferences every time you visit the Platform.
Security of Personal data
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 employees and third parties who reasonably need access to it to perform the activities attached to their job responsibilities.
Please be aware, however, that no data security measures can be guaranteed to be completely effective. Consequently, BaseCamptTrading.com 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.
Breach of Security
If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us might have been compromised), or if you suspect someone else is using your account, please contact us immediately as indicated in the “How to Contact Us” section.
Lost or Stolen Information.
You must promptly notify us if your credit, bank, other financial institution information, username, or password is lost, stolen, or used without permission. In such an event, we will assist you in updating your account details.
- Transfers of Personal Data
- 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 Not to Provide Consent or to Withdraw Consent
We seek to rely on your consent in order to process certain personal data. Where we do so, you have the right not to provide your consent, and the right to withdraw your consent at any time. If you withdraw your consent, this will not affect the lawfulness of the processing conducted based on consent before its withdrawal.
Right of Access
You have the right to obtain confirmation as to whether or not we collect or process personal data concerning you and, if this is the case, you have the right to request a copy of such personal data in digital format.
Right of Rectification
You have the right to require that we correct any inaccurate personal data concerning you, and that we complete incomplete personal data.
Right of Erasure
In certain circumstances, you have the right to request that we erase personal data concerning you; 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 the personal data that we have collected about you; for example, where you believe that the personal data that hold about you is not accurate or lawfully held.
Right to Data Portability
In certain circumstances, you have the right to receive the personal data concerning you that you have provided us in a structured, commonly used, machine readable format, and the right to obtain that we transmit the data to another entity where technically feasible.
Right to Object to the Processing
In certain circumstances, you have the right to request that we stop processing your personal data.
Right to Object to the Processing for Direct Marketing Purposes
You have the right to request that we stop sending you marketing communications.
Right Not to be Subject to Decisions Based Solely on Automated Processing that Produce Legal Effects
In certain circumstances, you have the right no to be subject to a decision based solely on automated processing - including profiling - that produces legal effects or similarly affects you.
Right to Complain to a Supervisory Authority
You have the right to lodge complaint with a supervisory authority if you believe that our processing of personal data relating to you infringes the GDPR.
- Rights of Users Located in California Residents
The California Consumer Privacy Act (“CCPA”) and other applicable California state privacy laws provide California residents with specific rights regarding their personal information. This section describes your rights under the CCPA and such other applicable laws and explains how to exercise those rights.
Access to Specific Information
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
· The categories of personal information we collected about you.
· The categories of sources for the personal information we collected about you.
· Our business or commercial purpose for collecting or selling that personal information.
· The categories of third parties with whom we share that personal information.
· The specific pieces of personal information we collected about you.
· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
o sales, identifying the personal information categories that each category of recipient purchased; and
o disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights
You have the right to request that we delete any of your personal information 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 information 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 information, 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 products 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 the information’s deletion may likely 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.
· Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
Exercising Access and Deletion Rights
To exercise the access and deletion rights described above, please submit a verifiable consumer request to us by contacting us at email@example.com. 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 information. 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 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 information associated with that specific account.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. We will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
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.
You do not need to create an account with us to exercise your opt-out rights. We will only use personal information provided in an opt-out request to review and comply with the request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by CCPA, we will not:
· Deny you goods or services.
· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
· Provide you a different level or quality of goods or services.
· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
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.
Some browsers give individuals the ability to communicate that they wish not to be tracked while browsing on the Internet. California law requires that we disclose to users how we treat do-not-track requests. The Internet industry has not yet agreed on a definition of what “Do Not Track” means, how compliance with “Do Not Track” would be measured or evaluated, or a common approach to responding to a “Do Not Track” signal. Due to the lack of guidance, we have not yet developed features that would recognize or respond to browser-initiated Do Not Track signals in response to California law. In the meantime, there are technical means to prevent some of the tracking, if any. See Section “Your Advertising Choices.”
- 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.
- Impact of EU-US Privacy Shield
- How to Contact Us