Last Updated: 12 December 2022
This privacy policy (“Privacy Policy”) is intended to provide you with specific details about how ETFtoad.com (“EFTtoad,” “we,” and “us”) collects and processes your personal and personally identifiable information through your use of our website, ETFtoad.com and associated services (“Website”). ETFtoad is the data processor and data controller of all information collected through the Website.
You understand and agree that ETFtoad may store and process your personal information on computers located outside of the European Union, including, but not limited to, in the United States. By using the Website, you agree to the collection and processing of your personal or personally identifiable information outside of the European Union.
Before using the Website or providing information to us, please carefully review this Privacy Policy. By using or accessing the Website, you agree that we may collect and use your personal and personally identifiable information in accordance with this Privacy Policy, as revised from time to time. ETFtoad may modify, amend, replace, or suspend this Privacy Policy at any time. If you have any questions or suggestions regarding our Privacy Policy, or if your personal information is not accurate or complete, please email us at info@etftoad.com
By providing ETFtoad with your personal or personally identifiable data and using the Website, you warrant that you are over the age of eighteen (18) or otherwise above the age of majority within your jurisdiction. If you are younger than eighteen (18) or the age of majority within your jurisdiction, please do not use the ETFtoad Website and please do not provide personal information to us.
- Personal Information Collected.
When you use the Website, we may collect personal or personally identifiable information from you (“PII”). PII may include any information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual. It does not include anonymized data.
We may collect and process the following categories of PII about you:
- Communication Data. Communication data includes any communication that you may send to us through the website, email, or social media. We process this data to communicate with you, to provide you with customer support, to record logs of our communication, and to store information to respond to legal claims. ETFtoad’s lawful ground for processing this communication data is to respond to communications sent by you to us, to keep records of our communication, and to pursue or defend against legal claims.
- User Data. User data includes data about how you use the Website and any data that you post to or authorize through the Website. This includes data stored in persistent cookies when you login to the Website and analytics data that is collected when you use the Website. We collect and process this data to operate the Website, to authenticate you as a user of the Website, to ensure that timely and relevant content is provided to you, to secure the Website, to ensure that the Website operates in a fast and efficient manner, and to maintain backups of the Website. ETFtoad’s lawful ground for processing this user data is its legitimate business interests in administering and offering the Website.
- Technical Data. Technical data includes data about your use of the Website, such as your IP address, your login data, your phone number, your mobile device model, your operating system, your geolocation, and your time zone. ETFtoad may collect this data from your use of the Website and from advertising IDs. ETFtoad processes this data to analyze your use of the Website, to route Website traffic, to administer and secure the Website, to provide location-relevant content, and to troubleshoot problems with the Website. ETFtoad’s lawful ground for collecting and processing this technical data is its legitimate interests in administering and offering the Website and to grow its business and marketing strategy.
- Marketing Data. Marketing data includes data about your preferences in receiving and interacting with ETFtoad’s advertisements or content on the Website. ETFtoad collects this data from your use of the Website and from advertising IDs created through advertising programs, such as Google Advertising IDs, TikTok Advertising IDs, and Apple Advertising IDs. ETFtoad does not connect advertising identifiers to persistent device identifiers, such as MAC addresses or mobile device IDs. ETFtoad’s lawful ground for collecting and processing this marketing data is its legitimate interests in administering and offering the Website and to grow its business and marketing strategy by providing advertisements, including remarketing advertisements, to you.
- Personally Sensitive Data. Personally sensitive data includes data about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, union membership, or information about your health. ETFtoad does not collect or use personally sensitive data through the Website.
ETFtoad will only use your PII for the purpose for which it was collected. In the event that ETFtoad needs to use your PII for an unrelated new purpose, ETFtoad will provide you with notice of this new use and will explain the lawful ground for such processing. ETFtoad may process your PII without your knowledge or consent where required or permitted by law.
ETFtoad does not use your PII to automatically make any decisions or to create an automated profile about you.
- Collection of Data From Third Parties.
ETFtoad may collect data about you through cookies and other technologies. This helps ETFtoad understand how you use the Website and to understand any patterns that may be associated with your use of the Website. This aids ETFtoad in developing or improving its Website in response to your needs or wants.
ETFtoad will use session or persistent cookies after getting your affirmative consent. Session cookies are only stored on your computer or mobile device during your use of the Website and are automatically deleted when you close your web browser. Session cookies may be used to direct internet traffic to a server that is closer to you or to allow us to identify you as you move between pages of the Website. Persistent cookies are stored as a file on your computer or mobile device that remains on your computer or mobile device even after you close your web browser. Persistent cookies can be read by the website that created the cookie when you revisit it again. ETFtoad may use persistent cookies to authenticate you when you return to the Website so that you do not have to login again or when it utilizes Google Analytics or other analytics providers, which is intended to track the origin and behavior of traffic to the Website. ETFtoad may use the following analytics providers, and you are directed to review their cookie policies:
Google Ads: https://policies.google.com/technologies/ads
CrazyEgg: https://www.crazyegg.com/privacy
ETFtoad may also receive data from third parties including analytics providers or advertising networks such as Google, Facebook, TikTok, or Apple. These third parties may be based outside of the European Union.
- Marketing Communications.
As stated above, ETFtoad’s lawful ground for sending you marketing communications is either consent or its legitimate business interests, such as to grow its business by advertising products to you. ETFtoad may send you marketing communications if you have asked for information concerning its goods or services or if you have agreed to, and have not opted out from, receiving marketing communications. You may ask ETFtoad to stop sending you marketing messages at any time by logging into the Website to adjust your marketing preferences within your User Account or by following the opt-out link in any marketing message sent to you. If you opt out of receiving marketing communications, your opt-out does not extend to PII provided for other purposes.
- Disclosure of Personal Information.
ETFtoad may share your PII with the following parties:
- Service providers that provide ETFtoad with information technology or other administrative services;
- ETFtoad’s accountants, auditors, insurers, or attorneys;
- Law enforcement agencies upon the receipt of a subpoena or court order or where necessary to protect ETFtoad’s personnel or property; and
- Government bodies that require ETFtoad to report its processing activities.
ETFtoad may also transfer PII to third parties when it sells, transfers, or merges any part of its business or assets.
ETFtoad requires all third parties that receive a transfer of PII from ETFtoad to maintain the same level of respect for the protection of PII as ETFtoad and ETFtoad only allows third parties to process your personal data for the specific purposes listed in this Privacy Policy.
- Data Security.
ETFtoad has put into place data security measures to protect your PII. ETFtoad allows access to your PII only by employees and service providers who have a need to know or on ETFtoad’ instructions. However, no security measures are impenetrable and there are always security risks. ETFtoad will notify you and any regulatory body of any breach of your PII or ETFtoad’s security measures if it is legally required to do so.
- Retention of Data.
ETFtoad will only retain your PII for so long as necessary to fulfill the purposes for which it is collected under this Privacy Policy or for the purposes of satisfying any legal, accounting, or reporting requirements. We will also retain and use your PII to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws, such as the California Consumer Privacy Act), resolve disputes, and enforce our legal agreements and policies.
- Right to Access, Rectification, Correction, Erasure, Transfer, and Withdrawal.
Under the law, you may have a right to request access to your PII for rectification, correction, erasure, transfer, or restriction, or to object to its processing or withdraw your consent. If you wish to exercise any of these rights, please contact ETFtoad’s Data Protection Officer as disclosed in this Privacy Policy.
You do not need to pay a fee to access your PII or to exercise your rights. However, ETFtoad may charge a reasonable fee if your request is unreasonable or excessive.
To confirm your request, ETFtoad may need to request specific information from you as a security measure to ensure that PII is not disclosed to an unauthorized third party. ETFtoad will attempt to respond to all legitimate requests within thirty (30) days.
- California Privacy Rights.
The following rules apply solely to visitors, users, and others who are residents of the State of California. California residents have the right to be notified which categories of PII are being collected and the purposes for which the PII is being used. In particular, we collected the following categories of PII (A, B, D, and F) as defined in the California Consumer Privacy Act within the last twelve months. Our uses of this PII are detailed above in this Privacy Policy:
Category | Examples | Collected |
A. Identifiers | Real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. | YES |
B. Personal information categories listed in the California Consumer Records statute (Cal. Civ. Code § 1798.80(e)) | Name, signature, address, telephone number, bank account number, credit card number, debit card number, or any other financial information. | YES |
D. Commercial | Records of products purchased. | YES |
F. Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
We obtain these categories of PII directly from California residents when they complete forms through our website or provide it to us as a part of a transaction or inquiry concerning our products. We also obtain these categories of PII indirectly from California residents while observing their actions on our Website and from third parties or service providers that they have authorized to receive and share PII.
California residents have a right to request that we disclose what PII we collect from you and whether, and how, we disclose or sell that PII. California residents may also request that we delete any personal information collected or maintained by us from you.
California residents may also have the right to opt out of the sale of their personal information by contacting us or, where available, by clicking a link or icon associated with an advertisement. Specifically, this link or icon may state “Do Not Sell My Personal Information” or “Do Not Sell My Info.” By selecting this link or icon, you “Opt Out,” which means that you have opted out of the sale of your personal information as set forth in the California Consumer Privacy Act. However, even though you may have opted out, you may still see interest-based advertisements. To learn more about interest-based advertising across websites and additional opt-out choices, you can visit http://optout.aboutads.info. If you opt-out of the sale of your personal information but do not opt out of interest-based advertising more generally, you may still receive ads tailored to your interests based on PII that was not sold by us, personal information that was sold to downstream participants at least 90 days before you opted out, or personal information that was sold by other sources from which you have not opted out.
To submit a request for a list of the categories of personal information collected from you or to request that ETFtoad delete your personal information, please email us at:
info@etftoad.com
To verify your request, we may request certain information from you to confirm that you are an ETFtoad user, such as your phone number, username, email address, city, state, or geographic location. You may also designate an authorized agent to make a request to ETFtoad to disclose or delete your personal information. To do so, you must provide ETFtoad with proof that the individual or business has been appointed as your agent, such by providing a signed power of attorney form, and provide accurate responses to any information requested by ETFtoad that may be necessary to confirm that you are a ETFtoad user, such as your phone number, username, email address, city, state, or geographic location. California residents have a right not to receive discriminatory treatment by ETFtoad for their exercise of these rights conferred under California law.
- Third Party Links.
ETFtoad’ Website may include links to third-party websites and applications. By clicking on third-party links, you may allow third parties to collect or share data about you. ETFtoad does not control these third-party links and you are advised to review their respective privacy policies.
- Responding to Do Not Track Signals.
You can generally opt-out of receiving personalized ads from third party advertisers and ad networks who are members of the Network Advertising Initiative (NAI) or who follow the Digital Advertising Alliance’s Self-Regulatory Principles for Online Behavioral Advertising by visiting the opt-out pages on the NAI website and DAA website. Our website is not currently set up to respond to browser do-not-track signals because there is no consensus within the advertising industry as to what “do not track” means in this context, but you can configure your browser settings to reject all cookies or prompt you before a cookie is set.
- Nevada Residents.
If you are a resident of Nevada, you may provide notice to us to limit the sale of your PII to third parties for resale or licensing purposes. However, we do not sell your PII for such use. To notify us that you wish to limit the sale of your PII to third parties for resale or licensing purposes, you may send us an email info@etftoad.com with the subject line, “Nevada Do Not Sell Request,” along with your name, address, and user account information.
- Children’s Privacy.
We do not direct the Website to anyone under the age of 13 and we do not knowingly collect PII from anyone under the age of 13. If you are a parent or guardian of an individual under the age of 13 and believe that we may have collected PII from your child, please contact us at info@etftoad.com.
- Notification of Changes.
Whenever ETFtoad changes its Privacy Policy, we will post those changes to this Privacy Policy on the Website and other places that we deem appropriate. Your use of the ETFtoad Website following these changes indicates your consent to the practices described in the revised Privacy Policy.
- Contact Us.
If you have any questions about this Privacy Policy or the manner by which we collect or use Personal Information about you, email us at info@etftoad.com.