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European and UK Privacy Policy of NinjaTrader

General Information and Introduction

In compliance with the United Kingdom’s and European Union’s General Data Protections Regulation No. 2472/1999 Law no 3471/200 (GDPR), this Privacy Policy is written to provide you with a clear description of NinjaTrader LLC’s and its affiliates, NinjaTrader Clearing LLC (DBA Tradovate), NinjaTrader Brokerage LLC and NinjaTrader LLC (“NinjaTrader” “us” and “we”) collect and use your personal data. This personal data may be gathered from your both directly, when you complete an application, provide us with documents or respond to an inquiry, as well as indirectly when you access our websites and trading services.

This Policy supplements our other policies and specific privacy notices and therefore should be read in conjunction with them. This privacy policy is not intended to govern any other privacy policies we may disseminate. Despite that this is our European and UK privacy policy, we are a U.S. entity and if you are or become a client of ours, in conformity with your contractual Customer Agreement with us, this supplemental Privacy Policy is governed by the laws of the State of Illinois. If you have any questions, please contact us, so that we may help answer any queries you may have regarding how and why we use your data.

Trading financial products is not suitable for children. Our services are not marketed towards children and we do not knowingly collect data of children.

NinjaTrader is the controller of any personal information that you provide us. That means we decide the purposes and means of the processing of that information and as a global service provider, we may transfer data abroad in connection with providing services to you. This could include countries outside the European Economic Area and UK.. NinjaTrader does and will not sell your personal information.

What Types of Personal Information We Collect:

How We Collect Your Personal Data

How We Use Your Personal Data

We will only use your data as allowed by law. We may, where permitted by law, use your personal information without your knowledge or consent if in compliance with the laws. In compliance with anti-money laundering laws and for the purpose of enforcing regulatory required identity theft policies, sanctions screening, and regulatory requests, as well as “know your customer” regulatory requirements, we must confirm your name, address and other information before opening an account for you. As a highly regulated financial institution, we do not rely solely on your consent to collect and use your person information. Under the GDPR, the legal basis for all our collection and use of personal data are as follows, (in some instances more than one legal basis may apply):

  1. Performance of a contract with you.
  2. Necessary to comply with a legal obligation
  3. Necessary for our legitimate interests (to keep records updated, prevent fraud, for provision of administration of services, network security, to run and develop our business services, for marketing development).

We also use your personal information to submit trade reporting to exchanges and regulators where required exchange rules and regulatory authorities.

As a potential client or client of ours we may use your personal information to contact you regarding your account status or responding to your questions or for marketing purposes.

If you are a client, we may use personal information to process your orders, facilitate payments to and from your account, manage your fees, collect debts, perform risk assessments, investigate complaints and disclose material we are required to report.

Marketing

Marketing is a legitimate business purpose one type of usage that we would like to provide details about. NinjaTrader will not sell your personal information for any reason. This includes trading you information for anything of value not just receiving money payment. We may however use your personal information (contact information, usage data, and technical information gathered) to determine what we think may be of interest or helpful to you. This is a way we assess which service, products or offers may be useful to you.

Disclosure and Why

We may share your personal information with the following parties:

Security

NinjaTrader has security measures in place to help prevent your information from being shared or accessed in an unauthorized manner, lost, or altered. Your personal information is accessible only to authorized employees of NinjaTrader and our authorized agents as disclosed above who have a need to know and use your information. With respect to your personal information, we require our employees and agents be subject to confidentiality requirements.

If there is a data breach, we have a written policy governing a proper response, including notification to you and applicable authorities when legally required.

How long do we keep your personal information?

As a financial institution providing products and service to you under somewhat heavy regulation, we are required to keep your personal information, including identity, contact, transaction and financial information for a minimum of 5 years after you stop being a client. Some data maybe be kept longer due to court or regulatory order. We strive to keep your information only as long as necessary to comply with legal and financial reporting and retention requirements. Request to delete your information may be sent to [email protected] for consideration.

Your rights

Generally, subject to regulation and law, under the data protection laws, you have the following rights:

If you wish to exercise any of these rights, please contact us at [email protected]

We will strive to accommodate reasonable and legal requests within a reasonable amount of time and generally in less than one month.