This Privacy Policy applies to the websites and services offered by Stage 5 Trading Corp. (referred to as “S5”, “we” or “us” in this Privacy Policy) and all other S5 related websites (collectively, the “Sites”), as well as all downloadable software, mobile applications, and other services provided by S5 and on which a link to this Privacy Policy is displayed (collectively, together with the Sites, our “Services”).

We respect individual privacy and value the confidence of our customers, employees, business partners, and others. We strive to collect, use, and disclose personal information in a manner consistent with the laws of the countries in which we do business and have a tradition of upholding the highest ethical standards in our business practices.

This Privacy Policy describes the personal information that we gather on or through our Services, how we use and disclose such information, the steps we take to protect your information, and the rights you may have related to our information collection and use practices. By visiting the Sites, or by purchasing or using our Services, you accept the privacy practices described in this Privacy Policy.

How and What Information We Collect

User-Provided Information. We collect personally identifiable information voluntarily provided by users or visitors of our Services (also referred to as “Users” or “you” in this Privacy Policy), including when you visit the Sites, use the Services, register an account, fill out forms on the Sites, or otherwise contact us. The personal information that we collect on or through our Services may include your first and last name, email address, mailing address, telephone number(s), organizational affiliation, payment services, credit card or other billing information, and any other information you choose to provide when you use the Services or otherwise interact with us.

Location Information. Some of our Sites and mobile apps also collect geo-location information. We use your location information to provide requested location-specific services. You may at any time opt-out from further allowing us to have access to your location data by turning off the location services in your mobile phone or browser settings. Please be aware that certain features of the mobile apps or website will not perform as expected if location services are turned off.

Automatically Collected Information. As is true of most websites and mobile applications, we or our third party service providers and partners (discussed below) collect information from you over time using automated means such as cookies, beacons, or online data analytics tools such as Google Analytics. This “automatically collected” information may include internet protocol (IP) addresses, MAC addresses, device IDs, device and browser type(s), referring/exit pages, operating system, date/time stamp, or clickstream data and other information about the way you use the Services. Depending on the jurisdiction in which you reside, this information may or may not be considered personal information. We also use these technologies to collect information regarding your interaction with S5-related links appearing on third-party websites or in a S5-generated email, such as whether you click on or forward a link or message. We may link this automatically collected data to other information you provide or we collect from you.

S5 does not directly track you when you visit other websites or engage in other activities online, so we do not register Do Not Track (DNT) signals from your browser.  However, you should review the privacy policies of other third parties that may be operating on our Sites (discussed below) to determine whether they honor DNT signals. For more information on “do not track” options, please see: http://donottrack.us/.

How We Use Your Information

We use the personal information we collect about you to solicit, service, and communicate with you or as otherwise disclosed in this Privacy Policy. In particular, we will use your information (a) as is necessary for the performance of contracts we have with you, or at your request prior to you entering into a contract with us (e.g., to send you product or billing information); (b) in ways that you likely expect and that will have minimal privacy impact in order to further our legitimate interests (e.g., to contact you following a tradeshow or to provide requested trial services); or (c) for any other purpose for which we have your consent (e.g., to send you ongoing marketing and promotional information). S5 does not use your personal information to make solely automated decisions about you or to make decisions about you that are likely to produce legal or similarly significant effects.

If you receive commercial emails from us, you may unsubscribe at any time by following the instructions contained within the email or by sending an email to the address provided in the “Contact Us” section below. Please be aware that if you opt-out of receiving commercial email from us, it may take up to ten (10) business days for us to process your request. Additionally, even after you opt-out from receiving commercial messages from us, you will continue to receive otherwise permitted administrative messages from us regarding the Services.

At times S5 may allow a customer to purchase or lease products or equipment and/or to make payments through the Services. In such event, S5 may also use a payment processing company to bill you for goods or services that you request. Currently S5 uses both PayPal, Inc.®, Stripe, Inc., and Spiffy.co as our payment processing options.  More information about these companies can be found at: https://paypal.com/, https://stripe.com/ , https://spiffy.co/ .  S5 takes all reasonable measures to select third-party agents for fulfillment and financial processing that agree to not retain, share, store, or use your personal or financial information for any other purposes than fulfilling orders or enforcing customer agreements.

We use analytics tools such as Google Analytics to analyze trends, administer and improve our Services, and track Users’ movements around the Services and on the Internet, and to gather demographic information about our user base as a whole. We believe that Google does not seek to identify individual users or to receive personally identifiable information except as may occur when they use your IP address.  This information helps us to improve our Services and deliver a better and more personalized service. Many of these companies, such as Google Analytics, collect and use information under their own privacy policies, which we encourage you to review. For more information about Google Analytics or their privacy policies, please visit the Google Analytics privacy page and/or the Google Partners’ Page. You may opt-out of Google Analytics web monitoring by following the instructions on the Google Analytics Web Monitoring Opt-Out page.

S5 may disclose your personal information if required to do so by law by its regulators including the NFA and CFTC, or in the good-faith belief that such action is necessary to: (a) comply with the law or legal process served on S5 or the Services; (b) protect or defend the rights of property of S5 and its Services; or (c) act in urgent circumstances to protect the personal safety of S5 employees, users of S5 products or services, or members of the general public.

S5 may only share your information with partners whose content or services that you have signed up for. S5 does not sell or rent your personal information to third parties. When you give us personal information, S5 will not share that information with third parties without your permission, other than for the limited exceptions and purposes described in this Privacy Policy or as otherwise permitted by applicable law.

Anti-Money Laundering

To help the government fight the funding of terrorism and money laundering activities, U.S. Federal law requires all financial institutions to obtain, verify and record information that identifies each person who opens an account. What this means to our Customers: When a Customer opens an account, we will ask the Customer for their name, address, date of birth and other information that will allow the Company to identify the Customer. The Company may ask to see the Customer’s driver’s license or other identifying documents. The Company may also seek to verify the information the Customer provides by checking various databases.

Use of Cookies

As mentioned above, the Services utilize ‘cookies’ to provide custom content, and to measure visitation patterns and user preferences. Cookies are small text files, downloaded onto your computer or mobile device when you visit certain websites. When you return to these websites — or visit other websites that use the same cookies — the websites recognize these cookies and your browsing device.

Our Sites use the following types of cookies:

1. Strictly Necessary Cookies. These cookies are essential, as they enable you to move around our Sites, and use various features, such as accessing secure areas. Without these cookies, some services cannot be provided. These cookies do not gather information about you for marketing or for remembering where you have been on the Internet. This category of cookie is essential for our Sites to work, thus they cannot be disabled.
2. Performance/Analytics Cookies. These cookies collect information about how you use the Sites. For example, the cookies will collect which pages you go to most often and if you get error messages from certain pages. These cookies do not gather information that identifies you. The information these cookies collect is anonymous and is only used to improve how our Sites work. These cookies are not used to target you with online marketing. Without these cookies we can’t learn how our Sites are performing and make relevant improvements that could better your browsing experience.
3. Functionality Cookies. These cookies allow us to remember choices you make and tailor our Sites to provide enhanced features and content to you. For example, these cookies can be used to remember your user name, password, and preferences, or to display popular content based on your historical interests on the Site. These cookies are not used to target you with online advertisements. While these cookies can be disabled, this may result in less functionality during your use of the Sites.
4. Third-Party Cookies. These are cookies that fall into one of the above categories, but are placed on your browsing device by a third party.We allow third parties with which we have a separate agreement to use cookies and other technologies to collect information about your use of the Sites, including, for example, when you view or interact with one of their advertisements on the Sites or to collect information about your interests when you view or interact with one of their advertisements. We do not share with these third parties any information that would readily identify you (such as email address); however, such parties have limited access to a small amount of information about your device, which is necessary to serve you advertisements on our Sites and on other sites across the Internet that are tailored to your apparent interests.

You can use the browser with which you are viewing the Sites to enable, disable or delete our (first party) cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable cookies, you may not be able to access certain areas of the Sites. Also, if you disable cookies other parts of the Sites may not work properly. You can find more information about how to change your browser cookie settings at allaboutcookies

While third parties that set cookies on our Sites provide a service to us or functionality, as noted above, you should review the third party’s websites, included those listed in the section above, for more information on how they use cookies or about how to opt-out of their cookie-based collection. For more general information about internet-based advertising or about opt out options related to the use of cookies for ad targeting, please go to www.aboutads.info.

EU Rights – Access, Correction, Deletion

Upon a reasonable request, end users in the European Economic Area may access, obtain a copy of, update, correct, or delete your personal data held by us at any time by contacting us using the information provided in the “Contact Us” section below. In order to comply with these requests, we may ask you to verify your identity. Please note that your rights may be limited in certain cases – for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or are required to keep pursuant to regulatory requirements.  Permissible changes will be reflected in our databases within a reasonable period of time.

S5 will retain your information for as long as your account is active or as needed to provide you services. Trading and Personal Identifying Information(PII) is retained by S5 as a result of regulatory requirements which govern our business. PII is held for at least five years after an account has closed. S5 will retain and use your personal information as necessary to comply with its legal obligations, resolve disputes, and enforce its agreements.

At any time, end users in the European Economic Area may object to the processing of your Personal Data, on legitimate grounds, except if otherwise permitted by applicable law.  Such users also have the right to file a complaint with the appropriate data protection authority.

Links and Third Party Websites

The Sites may contain links to other websites. Please be aware that we are not responsible for the privacy practices or the content of such other websites. We encourage our Users to read the privacy statements of each and every website they visit. This Privacy Policy applies solely to information collected by us through the Sites and does not apply to these third-party websites. The ability to access information of third parties from the Services, or links to other websites or locations, is for your convenience and does not signify our endorsement of such third parties, their products, their services, other websites, locations, or their content.

Also, S5 may allow select third parties to offer subscription services or fee-based products through the Sites. S5 makes no guarantees in regard to the policies of these parties, so you should investigate each site’s privacy policy before providing personally identifiable information to third parties.

Security Measures

S5 uses a variety of security measures to protect your personally identifiable information from unauthorized use, which may include but is not limited to, the use of SSL encryption. As noted above, the Sites may, contain links to other websites that are not controlled by S5. Please take all necessary precautions to protect your information when you visit one of these sites.

S5 does not guarantee and makes no representations or warranties that the Sites and access thereto are secure, or that the Sites are free of viruses or bugs that could result in damage to or the loss of data. You are responsible for protecting your data from viruses.

Children Should Not Provide Information to Us

None of our Services are intended for use by children, and we have no desire to collect information from those under the age of 18. S5 requests that children DO NOT provide information to us. In an instance where such information was collected it would be purely accidental and unintentional. If we become aware that information has been submitted by a child, the information will be deleted from the S5 databases. S5 encourages parents to discuss the Internet with their children and monitor personal information that a child may provide via the Internet.

Change in Ownership

In the event of a change in ownership of S5 as a result of a sale, merger, acquisition or bankruptcy, then S5 reserves the right to transfer all of your personal information to a separate entity. S5 will use commercially reasonable efforts to notify you (e.g., by posting on its Sites, issuing a press release, or notification by e-mail) of any change in ownership.

Policy Changes & Updating Information

S5 reserves the right to modify this Privacy Policy whenever the need arises. Updates to this Privacy Policy will be posted to the Services in a timely manner. When such updates are made, the “last updated” date at the top of this privacy policy will be modified. This policy is not a contractual agreement and does not provide you with any legal right. Unless otherwise specified, the Sites, its content, and its domain name and URLs are the sole property of S5.

Contact Us

If you have questions about anything contained in this Privacy Policy, including how your information is used, or how to access, correct, or delete your information, or how to opt-out of receiving information from S5, you may contact us at:

Stage 5 Trading Corp.
ATTN: Privacy/Marketing
700 N Green. Street, Suite 200
Chicago, IL 60642

Phone: 1-800-258-6675
Email: compliance@s5trading.com

S5 will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Privacy Policy.

Privacy Policy – California Supplement
(As provided by California Civil Code Section 1798.83)

A California resident who has provided personal data to a business with whom he/she has established a business relationship for personal, family, or household purposes (a “California Customer”) may request information about whether the business has disclosed personal information to any third parties for the third parties’ direct marketing purposes. In general, if the business has made such a disclosure or personal data, upon receipt of a request by a California Customer, the business is required to provide a list of all third parties to whom personal data was disclosed in the preceding calendar year, as well as a list of the categories of personal data that were disclosed. California Customers may request further information about our compliance with this law by emailing compliance@s5trading.com. Please note that Stage 5 Trading Corp. (“Stage 5” or “the firm”) is required to respond to one request per California Customer each year and that the firm is not required to respond to requests made by means other than through the email address above.

IMPORTANT INFORMATION FOR CALIFORNIA RESIDENTS
This section applies only to California residents. It describes how the firm collects, uses and shares Personal Information of California residents in operating its business, and their rights with respect to that Personal Information. For purposes of this section, “Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“CCPA”) but does not include information exempted from the scope of the CCPA.

YOUR CALIFORNIA PRIVACY RIGHTS
As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases the firm may decline your request as permitted by law.

INFORMATION
You can request the following information about how the firm has collected and used your Personal Information during the past 12 months: the categories of Personal Information the firm has collected; the categories of sources from which the firm collected Personal Information; the business or commercial purpose for collecting and/or selling Personal Information; the categories of third parties with whom the firm shares Personal Information; whether the firm has disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient; or whether the firm has sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.

ACCESS
You can request a copy of the Personal Information the firm has collected about you during the past 12 months.

DELETION
You can ask the firm to delete the Personal Information that has been collected from you.

OPT-OUT OF SALES
Stage 5 does NOT sell any of your Personal Information. If the firm were to do so in the future, you will be notified and you will have the opportunity to opt-out. In addition, if you direct the firm not to sell your Personal Information, the firm will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.

OPT-IN
If the firm knows that you are younger than 16 years old, the firm will ask for your permission (or if you are younger than 13 years old, your parent’s or guardian’s permission) to sell your Personal Information before we do so.

NONDISCRIMINATION
You are entitled to exercise the rights described above free from discrimination. This means the firm will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting the firm may penalize you as described above for exercising your rights.

HOW TO EXERCISE YOUR RIGHTS
You may exercise your California privacy rights described above as follows:

Right to information, access and deletion. You can request to exercise your information, access and deletion rights by writing to compliance@s5trading.com.

Right to opt-out of the “sale” of your Personal Information. The firm does not sell your Personal Information in the conventional sense (i.e., for money). However, like many companies, the firm uses services that help deliver interest-based ads to you. California law classifies our use of these services as a “sale” of your Personal Information to the companies that provide the services. This is because the firm allows them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads more likely to interest you.
You can request to opt-out out of this “sale” of your personal information here: Do Not Sell My Personal Information.

The firm will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. The firm cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. Except as described in this privacy policy, we will not use your personal information for any other purpose unless we describe how such information will be used at the time you disclose it to us or we obtain your permission to do so.

S5 will investigate and attempt to resolve complaints and disputes regarding use and disclosure of personal information by reference to the principles contained in this Privacy Policy.