Flett Exchange Privacy Policy



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.

We value our relationship with you and respect your right to privacy. Our Privacy Policy (“Privacy Policy”) covers Flett Exchange’s treatment of information that you provide to us or that we collect from you when you are visiting the website and when you use our products and services. This policy does not apply to the practices of companies that Flett Exchange does not own or control or to individuals whom Flett Exchange does not employ or manage, including operators of sites you may link to or from the Website or from which you link to the website. This Privacy Policy should be read in connection with the Flett Exchange User Agreement.

AGREEMENT


Please read this Privacy Policy carefully; it creates legal obligations. By using the Services and/or accessing our Website, you are acknowledging that you have read and understood this Privacy Policy and agree to be legally bound by it.

Any information you submit to us via our online forms or via email are provided on a voluntary basis. When you access our Site the collection, use and distribution of your information will be handled according to the terms and policies outlined in this Privacy Policy. By using this Site, you consent to collection and use of your information as described in this Policy, including personally identifiable information the Exchange may collect. If you object to any of the policies outlined in this Policy, we ask that you do not submit information to the Exchange or access our Site.

We may update or modify this Policy at any time. Any such updates or modifications will be effective upon posting on this Site, and your continued use of the Site will constitute your consent to any updated or modified Privacy Policy.

In addition, when you register as a user of any of the features of our Website (a “Subscriber”), during the registration process (and from time to time as Flett Exchange may require) you will be prompted to click an “I Accept,” “Submit” or similar button, which further confirms your agreement to be legally bound by this Privacy Policy.

SCOPE OF POLICY


This Privacy Policy applies only to information you provide to us online or that we collect from you while visiting or using our Website. It does not apply to information we have -obtained offline or through other means.

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.

  • Resellers: Flett Exchange may from time to time enter into agreements with companies that resell Flett Exchange's products or services, either on Flett Exchange's behalf, or on their own behalf on a private labeled basis and/or on a co-branded basis. Under the terms of these agreements, we may be required, and therefore we reserve the right, to share your personally identifiable information with such resellers. Once your personally identifiable information is provided to such resellers, it will no longer be covered by this privacy policy. In those instances, your personally identifiable information will be governed by the privacy policy of the resellers to whom it is provided. In such instances, users will be notified of this action thirty days before the event via email and / or by posting on our website.

  • 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;
OPTING OUT


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 info@flettexchange.com, 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.

NEWSLETTERS


Names and email addresses are used in sending newsletters. Out of respect for your privacy, we provide a way to unsubscribe from mailings and other material. Please see the opting out and requesting removal section of our privacy policy.

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 info@flettexchange.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.

FORUMS


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.

SERVICE-RELATED ANNOUNCEMENTS


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.

CUSTOMER SERVICE


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.

  • Third Parties: Except as described in this Privacy Policy, we do not share personally identifiable information with anyone, unless we have informed you of a change to our Privacy Policy and given you the opportunity to then choose to opt out. Once you have indicated that your information may be shared with third parties or you have responded to an offer by any third party on the Website, Flett Exchange can no longer update any of your personally identifiable information that has been transferred to such third parties or opt you out of such third parties so that you no longer receive their promotional and/or marketing information. Instead, you must either contact that third party or refer to its privacy policy to update your personally identifiable information or to let the third party know that you no longer want to receive promotional and/or marketing information about its products, services or offerings.


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.

AGE REQUIREMENT


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.
Flett Exchange reserves the right to change or modify this Privacy Policy from time to time, or to terminate this Privacy Policy. We will post notice of the new policy from the Privacy Policy link on the homepage of our Website. Your use of our Website following any such change constitutes your agreement to follow and be bound by the Privacy Policy, as changed. If we make any significant changes regarding disclosure of personally identifiable information to third parties, we will attempt to notify you prior to the date the modified policy takes effect.

If we decide to change our privacy policy, we will post those changes to this privacy statement, the home page, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.

RELATIONSHIP TO USER AGREEMENT


This Privacy Policy must be read in conjunction with Flett Exchange's User Agreement, and the provisions of the User Agreement incorporated herein.

YOUR CONSENT


By using our Website, you consent to our collection and use of your information, in accordance with this Privacy Policy. If you do not agree with some, or all of the terms of this Privacy Policy, you may choose not to become a User of Flett Exchange, or otherwise visit our Website.

CONTACT US


You may contact us for any reason by email or traditional mail at the following addresses, provided, however, if you wish to provide us with formal notice under our User Agreement or our Privacy Policy, you must provide your notice in writing, and mail it to the address set forth below.

Flett Exchange, LLC.
15 Exchange Place, Suite 710
Jersey City, NJ 07302

e-Mail: info@flettexchange.com

 

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Flett Exchange LLC. | 15 Exchange Place, Suite 710 Jersey City, NJ, 07302 | (201) 209-0234 | info@flettexchange.com

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Use of this Website constitutes acceptance of the Flett Exchange User Agreement, Site Disclaimer and Privacy Policy.