LAST REVISED May 19, 2022
1. Your Consent
2. The Information We Collect and How We Collect It
Stock-Trak collects a very limited amount of Personal Information from participants who register on its websites. In order to register, participants must first enter their date of birth. For persons under the age of 16, the only Personal Information we collect at the time of registration is their first name and the first initial of their last name. As a condition of registration, participants 16 years and over, provide us with their first name, last name and email address (which is optional). Other fields may be collected or used for demographic and marketing purposes or by 3rd party processors for payment processing purposes, including your credit card information.
As an alternative registration method, certain of our websites, including without limitation http://www.HowTheMarketWorks.com, http://www.PersonalFinanceLab.com, and http://www.NationalSMS.com, will provide the option to have third-party administrators register the individuals in the participation group. Third-party administrators who select this registration option can specify the number of user accounts needed and then the system will auto-generate their user accounts (usernames with passwords) for the third-party administrator to distribute directly to the participation group. With this method of account creation the user registration process is bypassed and no Personal Information is collected from users.
3. Purpose of the Information
Stock-Trak collects Personal Information from our participants to facilitate the functionality of its sites and/or educational purposes. First and Last Name (or First Name and First Initial of Last Name) allows third-party administrators to keep track of an individual participant’s performance, activities and participation group ranking. The information further allows us to contact participants to announce contest updates, new contests or any other information that may be of interest to a participant such as contacting the winners. In the event that we need to contact a user who wins a contest and we do not have their email address, then we would contact the third-party administrator. Email address is also used for certain transactional email messages on the website such as the registration confirmation email and change password requests.
4. To Whom We Disclose the Information
5. Internet Based Advertising
7. Data Security and Retention
At Stock-Trak we take numerous steps to ensure that the Personal Information of our users is securely maintained. Firstly, we only collect a minimal amount of Personal Information during the registration process and we may provide an option for third-party administrators to generate user accounts without providing any Personal Information. All the user data and Personal Information that we collect is stored in a fully managed, professional, web-hosting environment, which is SSAE 18 Type 2 SOC 2 compliant. The data hosting service features a managed firewall, daily data backups (offsite), restricted physical access, data encryption (SSL), redundancy and annual security audits. Personal Information and other data of inactive users gets purged from our database after 12 months of inactivity for participants and after 48 months for instructors (for example: teachers and professors).
9. Corrections, Modifications and Deletions of Personal Information
10. Data Controller
For purposes of the General Data Protection Regulation (the “GDPR”), we are the data controller for the purpose of data protection law, in respect of your Personal Information collected and used through your use of the websites, products and services. This is because we dictate the purpose for which your Personal Information is used and how we use your Personal Information.
11. Automated Decision Making
Stock-Trak will not use personal data for any monitoring or profiling activity or process, and will not adopt any automated decision making processes.
12. Your rights
Under the General Data Protection Regulation (GDPR), you have the following eight (8) rights:
- 1. The right to be informed; This means anyone processing your personal data must make clear what they are processing, why, and who else the data may be passed to.
- 2. The right of access; this is your right to see what data is held about you by a controller of your data.
- 3. The right to rectification; the right to have your data corrected or amended if what is held is incorrect in some way.
- 4. The right to erasure; under certain circumstances you can ask for your personal data to be deleted. This is also called ‘the Right to be Forgotten’. This would apply if the personal data is no longer required for the purposes it was collected for, or your consent for the processing of that data has been withdrawn, or the personal data has been unlawfully processed.
- 5. The right to restrict processing; this gives you the right to ask for a temporary halt to processing of personal data, such as in the case where a dispute or legal case has to be concluded, or the data is being corrected.
- 6. The right to data portability; you have the right to ask for any data supplied directly to the controller of the data, to be provided in a structured, commonly used, and machine-readable format.
- 7. The right to object; you have the right to object to further processing of their data which is inconsistent with the primary purpose for which it was collected, including profiling, automation, and direct marketing.
- 8. Rights in relation to automated decision making and profiling; you have the right not to be subject to a decision based solely on automated processing.
13. Transferring Data Internationally
Stock-Trak transfers personal data we have both collected from you and stored, to the Third-Party Processors located in countries outside EEA. These Third-Party Processors also include third-party ad networks. Stock-Trak shall not transfer such personal data to a country or territory outside the EEA unless the transfer is made to a country or territory recognised by the European Union as having an adequate level of data security, or is made with the your consent, or is made to satisfy the legitimate interest of Stock-Trak in regard to its contractual arrangements with its clients. We will comply with Data Protection Act 1998 in respect of any such transfer. By using this website, you consent to the transfer of your Personal Information to the Third-Party Processors located in countries outside the EEA.
14. Legal Bases for Processing Your Data
- • With your consent: We use the Personal Information you have provided us where you have given clear consent for the processing of your Personal Information for a specific purpose.
- • To comply with any legal or regulatory obligations (including in connection with a court order) and to protect and enforce Stock-Trak’s legal rights, interests and remedies to protect the business operations and customers of Stock-Trak or other persons.
- • To protect our legitimate interests: the processing is necessary for our legitimate business interests, unless there is a good reason to protect the individual’s Personal Information which overrides those legitimate interests. For example, we will use your Personal Information to provide you with the websites, products and services, customer support and service, for research and development purposes, and to protect your safety and security, including the monitoring of suspicious activity and fraud.
15. Data Breach
In the event of an unauthorized release, disclosure or acquisition of your Personal Information that compromises the security, confidentiality or integrity of your Personal Information maintained by Stock-Trak (“Data Breach”), Stock-Trak shall notify you within a reasonable time after the incident. Stock-Trak will adhere to all applicable governmental requirements with respect to such Data Breach related to your Personal Information. The security breach notification shall include, to the extent known by Stock-Trak, a list of the types of Personal Information that were or are reasonably believed to have been the subject of the Data Breach, and if known at the time of the notice, the date or estimated date of the Data Breach and a general description of the Data Breach incident. Stock-Trak will have a written incident response plan that reflects best practices and is consistent with industry standard and governmental authorities for responding to a Data Breach as relates to Personal Information.
16. Resolving Complaints
If you have any concerns about the way Stock-Trak is handling you Personal Information, please let us know immediately. You may email us directly at email@example.com with the subject “Privacy Concerns”. We will do our best to respond as soon as possible. You may also contact us at:
101 Marcel-Laurin Boulevard
Montreal, Quebec, H4N 2M3
Attention: Andrew Zeidel