Last Updated on: 03/01/2007
This document applies to flettexchange.com.
Website or Site pertains to flettexchange.com including the flettexchange web application.
The Flett Exchange web application (flettexchange.com/portal/) requires a login and password to perform trading in markets.
SCOPE OF POLICY
WHAT DO WE DO WITH THE INFORMATION WE COLLECT
In general, except as provided in this policy, we will not disclose your personally identifiable information to unaffiliated third parties without your express consent. There are, however, some limited circumstances in which we may need to disclose personally identifiable information about a user without express consent, including, but not limited to, the circumstances set forth below:
- Flett Exchange Website Vendors: We may employ other companies to perform functions on our behalf, such as fulfilling orders, providing customer service, sending print and electronic mail, processing credit card payments, or other functions necessary to our business. In order to allow these companies to perform their obligations, we may need to share your personally identifiable information with them. However, we will provide these companies with only that information necessary to perform their functions on our behalf, and we will not allow them to use your personally identifiable information for any other purpose.
- Imminent Harm: We may reveal your personally identifiable information to attorneys, private investigator organizations or law enforcement agencies if we believe that you are harming or interfering (or will imminently harm or interfere) with other Flett Exchange Users or anyone else or violating (either intentionally or unintentionally) the law or our Website Terms and Conditions of Use, or infringing any of Flett Exchange' legal rights.
- Legal: Flett Exchange will reveal your personally identifiable information, to the extent required to do so by law. If we receive legal process calling for the disclosure of any of your personally identifiable information we will attempt to notify you via the address you supplied during registration within a reasonable amount of time before we respond to the request, unless such notification is not permitted.
We reserve the right to disclose your personally identifiable information as required by law and when we believe that disclosure is necessary to protect our rights and/or comply with a judicial proceeding, court order, or legal process served on our Web site.
- Transfer of Website: Flett Exchange shall be entitled to transfer information it collects to a third party, including any personally identifiable information, in connection with a sale of all or substantially all of its assets.
In the event Flett Exchange, LLC goes through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of its assets, your personally identifiable information will likely be among the assets transferred. You will be notified via prominent notice on our Web site for 30 days of any such change in ownership or control of your personal information.
CHANGING OR REMOVING PERSONAL INFORMATION;
To maintain control over personally identifiable information, upon request this information is removed from our systems. Removal restricts your information from active use. Please understand that it may be impossible to completely eradicate all record of information due to issues such as backups and records of deletions.
Within the Flett Exchange web application members may log in with the user name and password then go to edit account to modify information previously submitted.
If you wish to remove your name and other personally identifiable information please send an email with the term "Unsubscribe" in the subject line to firstname.lastname@example.org, specifying any removal needed. As an alternative, you may request removal by writing our corporate headquarters using the information below.
In general, personally identifiable information is removed from our active databases within ten business days of receipt of the request.
If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them by following the unsubscribe instructions included in each newsletter or communication or by emailing us at email@example.com or you may contact us to opt-out by following the methods shown in the contact us section of the website.
You will be notified when your personal information is collected by any third party that is not our agent/service provider, so you can make an informed choice as to whether or not to share your information with that party.
Flett Exchange is not responsible for the personally identifiable information you choose to submit in forums such as bulletin boards, or chat rooms. This information submitted here may be read, collected, or used by other users of these forums and could be used to send you unsolicited messages.
On occasion service-related announcements are required. For instance, if service may be temporarily suspended for maintenance, an email informing users of potential disruption may be sent. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account. To deactivate your account contact us by following the methods shown in the contact us section of the website.
Based upon the personally identifiable information you provide us, we will also communicate with you in response to your inquiries to provide the services you request and to manage your account. We will communicate with you by email or telephone, in accordance with your wishes.
COMMUNICATION TO OUR USERS
- Flett Exchange: Flett Exchange sends emails and/or postal mailings to new subscribers and to provide to existing subscribers information regarding Flett Exchange products. As long as you use Flett Exchange's trading platform to buy or sell products or otherwise maintain a business relationship with Flett Exchange you may not opt out of receiving communications from Flett Exchange. The only way to stop receiving these emails is to deactivate the account.
SECURITY OF PERSONALLY IDENTIFIABLE INFORMATION
Flett Exchange maintains controls to protect the financial information you provide us, including credit card details, during the product purchase process. These controls include:
- The use of SSL encryption to safeguard information when transmitted from your web browser to Flett Exchange;
- The logical authentication security within the databases that store customers' credit card numbers; and
- Use of encryption of credit card numbers.
Flett Exchange employees strictly abide by our corporate policies with respect to the confidentiality of personally identifiable information. Moreover, Flett Exchange only gives access to databases containing personally identifiable information to employees on a need-to-know basis. Internal policies require that passwords be changed regularly, pursuant to security protocols. Our security procedures are reviewed on a periodic basis to ensure that they remain current.
Accordingly, we have put in place security systems designed to prevent unauthorized disclosure of information you provide to us. These systems are structured to deter and prevent hackers and others from accessing this information. Due to the nature of Internet communications and evolving technologies, however, we cannot provide, and disclaim, assurance that the information you provide us will remain free from loss, misuse, or alteration by third parties who, despite our efforts, obtain unauthorized access.
Persons under the age of eighteen (18) are not permitted to register as a Users of Flett Exchange and Flett Exchange does not knowingly collect, either online or offline, personally identifiable information from persons under the age of eighteen (18). If we learn that a person under (18) has provided us with personally identifiable information, we will delete this information from our databases, subject to any technical limitations on our ability to do so.
NOTIFICATION OF CHANGES
We reserve the right to modify this privacy statement at any time, so please review it frequently. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.
RELATIONSHIP TO USER AGREEMENT