Genesis Financial Technologies, Inc.

Published: August 6, 2020

Thank you for visiting tradenavigator.com, a Genesis Financial Technologies, Inc. website. This Privacy Policy (this "Policy") details our commitment to protecting the privacy of individuals who visit our websites, register to use the products and services that we market for subscription (the "Service"), or attend or register to attend sponsored events or other events at which Genesis Financial Technologies, Inc. participates. For the purposes of this Policy, the term, "website" shall refer collectively to www.tradenavigator.com as well as the other websites that Genesis Financial Technologies, Inc. operate and that link to this Policy.

This Policy is subject to change by Genesis Financial Technologies, Inc. (referred to throughout this Policy as "we", "our" and "us") at any time and at our discretion without notice by updating this posting. By using this website, you accept the terms and privacy practices contained in this Policy.

We understand the importance that Internet users place on privacy, and this Policy describes how we use personal information that is collected at our website.

Please read this Policy before using this website or submitting any personal information. California residents, please also see the section for additional rights that apply to you.

We take children's privacy very seriously. This website should only be accessed by persons eighteen (18) years or older. Due to the age restrictions of this website, none of the information obtained by this website falls within the Child Online Privacy Act (COPA). However, if your minor child has provided us with personally identifiable information, you may contact us if you want this information deleted from our records. We will then remove your child's information from the database that stores the information.

With the exception of your account information and other information we collect in connection with your registration or authentication into our Services, this Policy does not apply to our security and privacy practices in connection with your access to and use of the Services. These security and privacy practices, including how we protect, collect, and use electronic data, text, messages, communications or other materials that you submit to us and that are stored within the Services, are detailed in and governed by our End User License Agreement ("EULA"), or such other applicable agreement relating to your access to and use of such Services.

Subscribers to our Services ("Subscribers") are solely responsible for establishing policies for and ensuring compliance with all applicable laws and regulations, as well as any and all privacy policies, agreements or other obligations, relating to the collection of personal information in connection with the use of our Services by individuals with whom our Subscribers interact. We collect information under the direction of our Subscribers, and have no direct relationship with individuals whose personal information we process in connection with our Subscriber's use of our Services. If you are an individual who interacts with one of our Subscribers, please contact our Subscriber directly for assistance with any requests or questions relating to your personal information.

We may transfer personal information to companies that help us provide our Services. Transfers to third parties for these purposes are governed by the End User License Agreements with our Subscribers.

Individuals subject to European data protection laws may have data subject rights in relation to the personal data we hold on them (described in detail below). This may, in and of itself, be subject to limitations and/or restrictions.

If you are located in the EEA, please contact us to exercise your rights.

THE TYPE OF INFORMATION WE COLLECT FROM YOU

Like most places on the Internet, simply by visiting our website you automatically tell us certain information. This includes basic information such as your IP address, when you visited, the website from where you came prior to visiting us, the website where you go when you leave our website, your computer's operating system, and the type of web browser that you are using. Our website automatically records this basic information about you and stores it in log files. IP addresses may be considered personal data in certain jurisdictions, such as in the European Economic Area ("e;EEA"e;), and will be treated in accordance with this privacy policy.

We combine this automatically collected log information with other information we collect about you. We do this to offer special discounts and to improve marketing, analytics, and website functionality.

Technologies such as: cookies, beacons, tags and scripts are used by us and our marketing, advertising and support partners. These technologies are used in analyzing trends, administering the website, tracking users' movements around the website and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis.

We use cookies for our shopping cart, for user authentication and for user settings. Users can control the use of cookies at the individual browser level. If you reject cookies you may still use our website, but your ability to use some features or areas of our website may be limited. We may also collect any data that you provide us when you post it at our website (through our Contact Us page) or by email (such as your name and email address). You can always choose not to provide us with information. However, if you do choose not to provide certain information, we may deny you access to some or all of our website's services and features.

Any information you provide on our website order forms is collected by our payment processing service providers on their servers. That information is then shared with us. This information includes ordering information such as shipping and billing names and addresses, phone numbers, email address, and credit card information (See "Orders and Use of Personal Information" below). We use this information primarily to fulfill customer orders and requests. We do not share this information with any third parties. However, we may disclose personal information collected if we have received your permission beforehand or in very special circumstances, such as when we believe that such disclosure is required by law or other special cases described below.

Emails or newsletters that we send electronically may use techniques such as web beacons or pixel tags to gather email metrics and information to improve the reader's experience, such as the number of emails that are opened, whether they were forwarded or printed, the type of device from which they were opened, and the location (e.g. city and state) associated with the applicable IP address.

ORDERS AND USE OF PERSONAL INFORMATION

If you purchase a product or service from us, we request certain personal information from you on our order form. You must provide contact information (such as name, email, and shipping address) and financial information (such as credit card information and expiration date). We use this information for billing purposes and to fill your orders. If we have trouble processing an order, we will use this information to contact you.

We may also make some content, products and services available through our website or by emailing messages to you through cooperative relationships with third-party providers, where the brands of our provider partners appear on our website in connection with such content, products and/or services. We may share with our provider partners any information you provide, or that is collected, in the course of visiting any pages that are made available in cooperation with our provider partners. In some cases, the provider partner may collect information from you directly, in which cases the privacy policy of our provider partners may apply to the provider partners' use of your information. The privacy policy of our provider partners may differ from ours. If you have any questions regarding the privacy policy of one of our provider partners, you should contact the provider partner directly for more information.

By submitting your email address on this website, you agree to receive email from us. You can cancel your participation in any of these email lists at any time by clicking the opt-out link or other unsubscribe option that is included in the respective email. We only send emails to people who have authorized us to contact them, either directly, or through a third party. We do not send unsolicited commercial emails, because we hate spam as much as you do.

By submitting your email address, you also agree to allow us to use your email address for custom audience targeting on sites like Facebook, where we display custom advertising to specific people who have opted-in to receive communications from us.

In addition, you agree that by submitting your telephone contact information on this website and/or registering to receive the products and/or services offered herein, such act constitutes a purchase, an inquiry, and/or an application for the purposes of the Amended Telemarketing Sales Rule (ATSR), 16 CFR Part 310 et seq. and any applicable state and local "do not call" regulations. We retain the right to contact you via telemarketing in accordance with the ATSR and the applicable state regulations.

We ask for and may collect personal information such as your name, address, phone number and email address when you register for or attend a sponsored event or other events at which we participate.

WHAT WE DO WITH YOUR INFORMATION

We may use the information we collect about you (including personal information, to the extent applicable) for a variety of purposes, including to (a) provide, operate, maintain, improve, and promote the Services; (b) enable you to access and use the Services; (c) process and complete transactions, and send you related information, including purchase confirmations and invoices; (d) send transactional messages, including responses to your comments, questions, and requests; provide customer service and support; and send you technical notices, updates, security alerts, and support and administrative messages; (e) send promotional communications, such as providing you with information about products and services, features, surveys, newsletters, offers, promotions, contests, and events; and provide other news or information about us and our partners. You can opt-out of receiving marketing communications from us by contacting us at support@tradenavigator.com or following the unsubscribe instructions included in our marketing communications; (f) monitor and analyze trends, usage, and activities in connection with the website and Services and for marketing or advertising purposes; (g) investigate and prevent fraudulent transactions, unauthorized access to the Services, and other illegal activities; (h) personalize the website and Services, including by providing features or advertisements that match your interests and preferences; and (i) for other purposes for which we obtain your consent.

As a general rule, we will not share, sell, rent or trade your data with third parties without your permission. However, there are some important exceptions to this rule that are described in the following paragraphs.

We may, in our sole discretion, provide information about you as required by law and when we believe that disclosure is necessary to protect our rights and/or to comply with a judicial proceeding, court order, or other legal process for purposes of fraud investigations, alleged intellectual property infringement, or any other suspected illegal activity or matters that may expose us to legal liability.

Although we do not disclose individually identifiable information, we may disclose aggregate data about our website's visitors to advertisers or other third parties for marketing and promotional purposes.

We share information, including personal information, with our third-party service providers that we use to provide hosting for and maintenance of our website, application development, backup, storage, payment processing, analytics and other services for us. These third-party service providers may have access to or process your personal information for the purpose of providing these services for us. We do not permit our third-party service providers to use the personal information that we share with them for their marketing purposes or for any other purpose than in connection with the services they provide to us.

If we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal information will likely be among the assets transferred. You will be notified via email and/or prominent notice on our website for 30 days of any such change in ownership or control of your personal information.

BEHAVIORAL TARGETING / RE-TARGETING

We partner with third parties to either display advertising on the website or to manage our advertising on other websites. Our third party partners may also use technologies such as cookies to gather information about your activities on our website and other websites in order to suggest advertisements based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union you may opt-in the use of cookies, by clicking here).

HOW LONG WE RETAIN YOUR PERSONAL INFORMATION:

We will retain your personal information for as long as is needed to fulfill the purposes outlined in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible. For personal information that we process on behalf of our Subscribers, we will retain such personal information in accordance with the terms of our agreement with them, subject to applicable law.

ACCESS TO PERSONAL INFORMATION

Upon request we will provide you with information about whether we hold, or process on behalf of a third party, any of your personal information. To request this information please contact us at support@tradenavigator.com. Subscribers to our Services may update or change their account information by editing their profile or organization record or by contacting support@tradenavigator.com for more detailed instructions. To make a request to have personal information maintained by us returned to you or removed, please email support@tradenavigator.com. Requests to access, change, or remove your information will be handled within thirty (30) days.

An individual who seeks access to personal information, or who seeks to amend or delete personal information stored or processed by us on behalf of one of our Subscribers, should direct his/her query to the Subscriber. Upon receipt of a request from one of our Subscribers for us to remove or amend the data, we will respond to their request within thirty (30) days. We will retain personal information that we store and process on behalf of our Subscribers for as long as needed to provide the Services to our Subscribers. We will retain and use this personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

If you are a Subscriber or otherwise provide us with personal information in connection with your use of our website or Services, we will delete this information upon your request, provided that, notwithstanding such request, this information may be retained for as long as you maintain an account for our Services, or as needed to provide you with our Services, comply with our legal obligations, resolve disputes and enforce our agreements.

OPTING-OUT

We provide you the opportunity to opt-out from any promotional, marketing, or informational emails that we may send you. You may do so by following the instructions included in each communication or by emailing us at support@tradenavigator.com.

SECURITY

The security of your personal information is important to us. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

When you enter sensitive information (such as a credit card number) on order forms that are hosted by our PCI compliant third-party service providers, the transmission of that information is encrypted using secure socket layer technology (SSL).

If you have any questions about the security of your personal information, you can contact us at support@tradenavigator.com.

GOOGLE ANALYTICS

We use Google Analytics Advertiser Features to optimize our business. Advertiser features include:

• Remarketing with Google Analytics
• Google Display Network Impression Reporting
• DoubleClick Platform Integrations
• Google Analytics Demographics and Interest Reporting

By enabling these Google Analytics Display features, we are required to notify our website visitors by disclosing the use of these features and that we and third-party vendors use first-party cookies (such as the Google Analytics cookie) or other first-party identifiers, and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to gather data about your activities on our website. Among other uses, this allows us to contact you if you begin to fill out our check-out form but abandon it before completion, with an email reminding you to complete your order. The "Remarketing" feature allows us to reach people who previously visited our website, and match the right audience with the right advertising message.

You can opt out of Google's use of cookies by visiting Google's ad settings, and you may opt out of a third-party vendor's use of cookies by visiting the Network Advertising Initiative opt-out page.

FACEBOOK

As advertisers on Facebook and through our Facebook page, we (not Facebook) may collect content or information from a Facebook user and such information may be used in the same manner specified in this Policy. You consent to our collection of such information. We abide by Facebook's Data Use Restrictions.

• Any ad data collected, received or derived from our Facebook ads ("Facebook advertising data") is only shared with someone acting on our behalf, such as our service provider. We are responsible for ensuring that our service providers protect any Facebook advertising data or any other information obtained from us, limit our use of all of that information, and keep it confidential and secure.
• We do not use Facebook advertising data for any purpose (including retargeting, commingling data across multiple advertisers' campaigns, or allowing piggybacking or redirecting with tags), except on an aggregate and anonymous basis (unless authorized by Facebook) and only to assess the performance and effectiveness of our Facebook advertising campaigns.
• We do not use Facebook advertising data, including the targeting criteria for a Facebook ad, to build, append to, edit, influence, or augment user profiles, including profiles associated with any mobile device identifier or other unique identifier that identifies any particular user, browser, computer or device.
• We do not transfer any Facebook advertising data (including anonymous, aggregate, or derived data) to any ad network, ad exchange, data broker or other advertising or monetization related service.

Do Not Track Disclosure

Some browsers or other tools include "e;Do Not Track"e; (DNT) features which, when turned on, send a signal to websites you visit indicating you do not wish to be tracked across websites over time. However, since no technology standard for DNT signals has been developed or adopted to date, Trade Navigator may not properly respond to DNT signals.

Collection of Personal Financial Information by a Payment Service

In some cases, we may use an unaffiliated payment service to allow you to purchase a product or make payments ("e;Payment Service"e;). If you wish to purchase a product or make a payment in such a case, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service's privacy notice, rather than this Privacy Notice. We have no control over, and are not responsible for, any Payment Service's use of information collected through any Payment Service.

LINKS TO OTHER SITES

Our website contains links to other sites that are not owned or controlled by us. Please be aware that we are not responsible for the privacy practices of such other sites.

We encourage you to be aware when you leave our website and to read the privacy policies of each and every website that collects personal information.

This Policy applies only to information collected by our website.

TESTIMONIALS

We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at support@tradenavigator.com.

Nevada Residents

We are providing you with this notice pursuant to state law. You may be placed on our internal Do Not Call List by calling 800-326-7141. Nevada law requires that we also provide you with the following contact information: Bureau of Consumer Protection, Office of the Nevada Attorney General, 555 E. Washington St., Suite 3900, Las Vegas, NV 89101; phone number: 702-486-3132; email: BCPINFO@ag.state.nv.us.

Vermont Residents

In accordance with Vermont law, we will not share information we collect about Vermont residents with companies that are not affiliates, except as permitted by law, such as with your consent or to service your accounts. We will not share information about your creditworthiness with our affiliates without your authorization or consent, but we may share information about our transactions or experiences with you with our affiliates without your consent.

California Residents

In accordance with California law, we will not share information we collect about you with nonaffiliates, except as allowed by law. For example, we may share information with your consent or to service your accounts. Among our affiliates, we will limit information sharing to the extent required by California law. We do not sell personal information.

Because we are a financial institution subject to other federal privacy laws, the California Consumer Protection Act does not apply to our clients' personal information.

California residents may have certain rights under the CCPA, many of which are subject to limitations or exceptions under applicable law:

Right to Know

You may have the right to request the following information about the Personal Data or Other Information we may have collected about you during the past 12 months:

• the categories and specific pieces of Personal Data and Other Information we may have collected about you
• the categories of sources from which we collected the Personal Data and Other Information
• the business or commercial purpose for which we collected or sold the Personal Data and Other Information
• the categories of third parties with whom we shared the Personal Data and Other Information
• the categories of Personal Data and Other Information we sold (per CCPA), or disclosed for a CCPA business or commercial purpose
• the categories of third parties to whom we sold (per CCPA), or disclosed for a CCPA business or commercial purpose, that information.

Right to Delete

You may have the right to request that we delete the Personal Data and Other Information we have collected from you. Certain information may be exempt from such requests under applicable law. In addition, we may need to retain certain information for recordkeeping purposes and/or to provide our Services to you. If you submit a request to delete, you may no longer be able to access or use our Services.

Right to Nondiscrimination

We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise CCPA Privacy Rights.

Data Subject Request

Submit your access or deletion request here:
For California Consumer Privacy Act specific questions, please call 800-582-0387.

12.0 Contact Us

You may contact us for any reason by email or traditional mail at the following addresses, provided, however, if you wish to provide us with formal notice under our Website Terms and Conditions or our Privacy Policy, you must provide your notice in writing, either mail it to the address set forth below or the email address below:

By mail:

By Email:

support@tradenavigator.com