Vanquish Trading

Website Privacy Notice

We appreciate the importance of maintaining the confidentiality of your personal information. This notice describes the types of personal information we collect about our website visitors and other individual consumers with whom we interact (collectively, “Consumers”). This notice explains what we do with this information and the ways that we protect your privacy. This notice also provides disclosures pursuant to, where applicable, the California Consumer Protection Act (the “CCPA”), other U.S. state comprehensive privacy laws (together with the CCPA, “U.S. State Privacy Laws”), the General Data Protection Regulation 2016/679 (the “EU GDPR”), the retained EU law version of the GDPR (the “UK GDPR”) (together the “GDPR”) and other United Kingdom (the “UK”) and EU privacy laws (together, the “Privacy Laws”). In this notice, the terms “we,” “our” and “us” refer to Vanquish Trading (the data controller under applicable Privacy Laws), [and its affiliates, including [specific affiliated entiy(ies)] and their managers, partners, principals, registered representatives and agents, whether such individuals are engaged directly by us as employees or as independent contractors,] to the extent relevant to the processing of your personal information (collectively, “Vanquish” and individually, a “Vanquish Party”).

1. Types of Personal Information We Collect

We collect and maintain the following types of personal information about Consumers, including:

• Personal identification information (e.g., name, address, telephone/fax numbers, electronic addresses); and
• Network activity information (e.g., browsing information, IP addresses, and other unique personal identifiers).
• Trade information (e.g., trades made, amounts invested, and returns).
• Cookie data (our website uses cookies, pixel tags, software development kits, statistical identifiers, and similar technologies (referred to as “cookies and similar technologies”) to collect and store certain data such as log data, location data, and cookie data when you visit or interact with our website).

The source of this personal information is you, when you provide information to us or when we collect information passively via our website, in the case of network activity information and cookie data. We may also collect personal information about Consumers from our vendors, third parties, and from publicly-available sources.

1. How We Use Your Personal Information

We collect, use, and disclose personal information we collect about Consumers for the following purposes:

• To analyze use and performance of our websites;
• For our legitimate business activities;
• To satisfy our compliance requirements;
• To fulfill our contractual obligations;
• To analyze, improve, and promote our services, including for marketing purposes;
• To communicate with you, such as if you contact us with a question;
• To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with products, services, and advertisements for such purposes; and
• To comply with applicable law, and to exercise and defend our rights and the rights of others.

We may also aggregate and/or anonymize personal information and analyze those data for statistical or any other purposes permitted by law.

1. How We Disclose Personal Information

We disclose personal information we collect about Consumers in the following contexts:

• To our affiliates, and to vendors who process your personal information on our behalf
• To third parties with your consent or at your direction
• To comply with the law or respond to compulsory legal process (such as a search warrant or court order) or request for information from a regulator or otherwise for legal purposes or disputes or investigations.
• To verify or enforce compliance with the policies governing the services we provide to you.
• To protect the rights, property, or safety of Vanquish or Vanquish funds or any of our respective business partners, or clients or otherwise in the legitimate business interests of Vanquish and Vanquish funds and in accordance with applicable laws.
• In connection with the sale, assignment, merger, or other transfer of all or a portion Vanquish’s business to that third party.

1. Protecting Personal Information from Unauthorized Access

Safeguarding the confidentiality, security, and integrity of your personal information is very important to us. We have established systems, policies, and procedures designed to protect your personal information physically, electronically, and procedurally from being accessed by unauthorized persons. Employees are trained in our privacy policies and procedures, including the proper handling of personal information. Employee access to personal information is limited to those with a legitimate business reason for such access. However, while the security of your personal information is of the utmost importance to us, please be aware that we cannot fully guarantee the security of any information you choose to disclose online.

1. Additional Disclosures For EEA/UK Residents

If you are a resident of the UK or the European Economic Area (“EEA”), we may transfer your personal information to Vanquish in the U.S., which has a lower standard of data privacy laws compared to the GDPR, for the purposes described above.

Where your personal information is processed by service providers or third parties outside the UK and/or EEA, we will ensure appropriate safeguards are in place to adequately protect it, as required by applicable law, including the execution of specific contracts approved for use in the UK or EU as determined by the European Commission or the Information Commissioner’s Officer (as applicable) if the recipients are not located in a country with adequate data protection laws (as determined by the European Commission or the Information Commissioner’s Office).

If you reside in the UK or EEA, the applicable legal bases for our processing of your personal information include the following:

• Based on your consent: In some cases, at the point at which you provide personal information, we may ask you for your consent to collect and process your personal information. If you choose to provide us with your consent, you may later withdraw your consent (or opt-out) by contacting us as described below. Please note that if you withdraw your consent it will not affect any processing of your personal information that has already occurred. Where we process your personal information based on consent, we will provide more detailed information to you at the time when we obtain your consent.
• Compliance with applicable laws or performance of a contract: In specific circumstances, we may need to process your personal information to comply with a relevant law/regulation or to fulfill our obligations under a contract to which you are subject. Where we process your personal information to meet our legal obligations, you will likely not be permitted to object to this processing activity, but you will usually have the right to access or review this information unless it would impede our legal obligations. Where we are processing your personal information to fulfill our obligations under a contract to which you are a party, you might not be able to object to this processing, or if you do choose to opt-out or object to our processing, it may impact our ability to perform a contractual obligation that you are owed.
• Our legitimate interest: We may process your personal information based on our legitimate interests in communicating with you and managing our interactions with you regarding our products and services, investment research, and educational opportunities. In addition to other rights you may have as described below, you have the right to object to such processing of your personal information. You can register your objection by contacting us as described below.

Residents of the UK and EEA have certain rights relating to the personal information we hold in accordance with and subject to the European Privacy Laws to: (i) check whether we hold personal information about you and to access such data (in accordance with our policy); (ii) request the correction of personal information about you that is inaccurate; (iii) have a copy of the personal information we hold about you provided to you or another controller where technically feasible; (iv) object to the processing of your personal information; (v) request the erasure of personal information; (vi) request the restriction of personal information processing activities; and (vii) make a complaint to a supervisory authority in the Consumer’s country of residence. All of these rights are subject to applicable exemptions and restrictions under applicable European Privacy Laws. We will endeavor to respond within a month of the request and will confirm if this is not feasible, for reasons relating to the complexity of a request, within the first month and extend the timeline by a further two months if necessary.

1. Additional Disclosures for U.S. Consumers

For additional disclosures pertaining to Consumers who reside in the U.S., please see our Supplemental U.S. Privacy Notice, below.

Children’s Privacy

Our website is not intended for children under age 13 and are not designed to attract the attention of anyone under age 13. Further, for compliance with the Children’s Online Privacy Protection Act of 1998, we do not knowingly collect personal information of children under age 13. If you are a parent or guardian and believe we have collected personal information about your child in error, please contact us immediately at [privacy email address] so that we can make reasonable efforts to promptly remove all personal information relating to the child from our systems.

Third-Party Links on Our Website

Our website may contain links to pages owned by third parties. If you decide to use these links, you will leave our website. We are not responsible for the privacy practices or the content of such third parties, and we make no representations or endorsements about them. If you decide to leave our website to access third party links, it will be at your own risk, and this notice will no longer govern. You should review the applicable terms and policies, including privacy and data gathering practices, of any other third party when you navigate away from our website.

Changes to this Notice

We may update this notice periodically. The latest version will be posted on our website.

1. Contact Us

If you have any questions about our privacy practices, please contact us at privacy@vanquishtrader.com.

Last Updated: 08/29/2024

Vanquish Trading

Supplemental U.S. Privacy Notice

This Supplemental U.S. Privacy Notice (the “Supplemental Notice”) provides additional information for Consumers who are residents of states with comprehensive privacy legislation that apply to us, including California (the “U.S. State Privacy Laws”).

Some portions of this Supplemental Policy only apply to consumers who reside in particular U.S. states. In those instances, we have indicated that such language applies only to those residents.

1. Definitions

• “Personal information” means 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. Personal information includes “personal data” (or equivalent terms) as that term is defined by U.S. State Privacy Laws.
• “Vendor” means a service provider, contractor, or processor as those terms are defined by U.S. State Privacy Laws.
• “Third Party” means any entity that is not us or a vendor.

Other terms used herein that are defined terms under U.S. State Privacy Laws shall have the meanings afforded to them by the U.S. State Privacy Laws, whether or not capitalized, unless the context indicates otherwise. As there are some variations between such definitions across the U.S. State Privacy Laws, the definitions applicable to you are those provided in the statute for the U.S. state in which you are a Consumer. For example, if you are a California Consumer, terms used in this Supplemental Policy that are defined terms in the California Consumer Privacy Act (“CCPA”) shall have the meanings afforded to them in the CCPA as this Supplemental Notice applies to you.

1. Overview of Personal Information Processing

1. Collection of Personal Information. We collect and we have collected in the past twelve months the following categories of personal information:

• Personal identification information (e.g., name, address, telephone/fax numbers, electronic addresses); and
• Network activity information (e.g., browsing information, IP addresses, other unique personal identifiers, and cookie data).
• Commercial information (i.e., trade information, such as trades made, amounts invested, and returns).

We do not collect sensitive personal information, as defined by the CCPA, or use sensitive personal information for purposes not permitted by the CCPA.

2. Sources of Personal Information. The source of this personal information is you, when you provide information to us or when we collect information passively via our website, in the case of network activity information. We may also collect personal information about Consumers from our vendors, third parties, and from publicly-available sources.

3. How We Use Your Personal Information. We collect, process, and disclose the categories of personal information listed in Section II(1):

• To analyze use and performance of our websites;
• For our legitimate business activities;
• To satisfy our compliance requirements;
• To fulfill our contractual obligations;
• To analyze, improve, and promote our services, including for marketing purposes;
• To communicate with you, such as if you contact us with a question;
• To identify you and your device(s) for any/all purposes identified above, including to monitor your use of and interactions with products, services, and advertisements for such purposes; and
• To comply with applicable law, and to exercise and defend our rights and the rights of others.

We may also aggregate and/or anonymize personal information and analyze those data for statistical or any other purposes permitted by law.

4. How We Disclose Personal Information. Further, we disclose and have disclosed the categories of personal information listed in Section II(1) to the following categories of entities for a business purpose in the past twelve months:

• To our affiliates, and to vendors who process your personal information on our behalf
• To third parties with your consent or at your direction

As needed, we may also disclose the categories of personal information listed in Section II(1) in the following situations:

• To comply with the law or respond to compulsory legal process (such as a search warrant or court order) or request for information from a regulator or otherwise for legal purposes or disputes or investigations.
• To verify or enforce compliance with the policies governing the services we provide to you.
• To protect the rights, property, or safety of Vanquish or Vanquish funds or any of our respective business partners, or clients or otherwise in the legitimate business interests of Vanquish and Vanquish funds and in accordance with applicable laws.
• In connection with the sale, assignment, merger, or other transfer of all or a portion Vanquish’s business to that third party.

5. Sale, Sharing, & Processing for Purposes of Targeted Advertising. We do not sell or share personal information, and we have not sold and shared personal information in the past twelve months. Further, we do not process personal information for purposes of targeted advertising. We also do not have actual knowledge that we sell or share personal information of California consumers under 16 years of age. For purposes of the CCPA, a “sale” is the disclosure of personal information to a third party for monetary or other valuable consideration, and a “share” is the disclosure of personal information to a third party for cross-context behavioral advertising, whether or not for monetary or other valuable consideration.

6. Retention of Personal Information. We will retain each category of personal information listed in Section II(1) for a reasonable period based on the context of our interaction with you and the purposes for which we collected such information. Thereafter, we will delete (or otherwise erase, de-identify, anonymize, or equivalent) any such personal information except as required or permitted by applicable law or regulation.

1. Do Not Track & Opt-Out Preference Signals

Because we do not sell or share personal information, our websites are not currently configured to recognize opt-out preference signals, including “Do Not Track” signals. If and when our websites recognize opt-out preference signals, we will update this Supplemental Notice to provide further details about how our websites do so.

1. Your Rights & Choices

Consumers who reside in states with U.S. State Privacy Laws have the following rights regarding our collection and use of their personal information, subject to certain exceptions. Please read this section carefully as some rights vary by state. When we process your request, we will do so in accordance with the U.S. State Privacy Law applicable to you based on your state of residence.

You may exercise the data subject rights below by calling [toll-free number] or by clicking [here] and submitting details regarding your request. You may also authorize an agent to make data subject requests on your behalf. In such instances, authorized agents may use the same methods as you to submit the requests on your behalf. To verify your identity and protect your personal information, we may ask the requestor to provide information that will enable us to verify your identity in order to comply with your data subject request, such as asking your agent to provide proof of signed permission from you, or ask you to confirm with us directly that you provided the agent with permission to submit the request. In some instances, we may decline to honor your request if an exception applies under applicable law. We will respond to your request consistent with applicable law.

• Right to Know: You have the right to know the following details about our privacy practices at or before the point of collection. We have provided such information in this Supplemental Notice. You may also request that we provide you with information about the following aspects of how we have handled your personal information specifically in the twelve months preceding your request:
  • The categories of personal information we have collected about you;
  • The categories of sources from which we collected such personal information;
  • The business or commercial purpose for collecting, selling, or sharing personal information about you;
  • The categories of personal information about you that we disclosed and the categories of third parties to whom we disclosed such personal information;
  • The categories of personal information about you that we sold, shared, or used for targeted advertising purposes, and the categories of third parties with whom we sold or shared such personal information; and
  • The length of time we intend to retain each category of personal information, or if that is not possible, the criteria used to determine that period.
• Right to Deletion: You may request that we delete any personal information about you we that we collected from you.
• Right to Correction: You may request that we correct any inaccurate personal information we maintain about you.
• Right to Access Specific Pieces of Personal Information and Data Portability: You may ask to obtain the specific pieces of personal information we have collected about you in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the personal information to another entity without hindrance. You may not exercise this right more than two times in a calendar year.
• Right to Non-Discrimination: You have the right not to receive discriminatory treatment for exercising your data subject rights. We will not discriminate against you for exercising any of the rights described above. For example, we will not deny services to you or provide a different level of quality of services to you as a result of you exercising your data subject rights.

To appeal our decision on your data subject requests, you may contact us at [privacy email address]. Please enclose a copy of or otherwise specifically reference our decision on your data subject request, so that we may adequately address your appeal. We will respond to your appeal in accordance with applicable law.

1. Other Disclosures for California Consumers

• California Residents Under Age 18.If you are a resident of California under the age of 18 and a registered user of our website, you may ask us to remove content or data that you have posted to our website by writing to [privacy email address]. Please note that your request does not ensure complete or comprehensive removal of the content or data, as, for example, some of your content or data may have been reposted by another user.
• Disclosure About Direct Marketing for California Residents. California Civil Code § 1798.83 permits California residents to annually request certain information regarding our disclosure of personal information to other entities for their direct marketing purposes in the preceding calendar year. We do not disclose personal information to other entities for their direct marketing purposes.
• Financial Incentives for California Consumers. We do not provide financial incentives to California Consumers who allow us to collect, retain, sell, or share their personal information. We will describe such programs to you if and when we offer them to you.

1. Disclosure for Nevada Consumers

We do not sell “Covered Information” as defined under Nevada law, or disclose “Personal Information” as defined under Nevada law for commercial purposes.

1. Contact Us

If you have any questions regarding this Supplemental Notice or our websites generally, please contact us at privacy@vanquishtrader.com.

We may update this Supplemental Notice from time to time. When we do so, we will post the updated version of our Supplemental Notice here.

Last Updated: 08/29/2024