Privacy Notice

1. Overview

NinjaTrader Group, LLC together and its subsidiary companies, NinjaTrader Brokerage, LLC and NinjaTrader, LLC (together “NinjaTrader”) take personal data privacy seriously. The main purpose of this Privacy Policy is to inform you of how personal information we obtain from you is treated when you use NinjaTrader’s products, services, and websites.

2. What we need

Our Personal Data Protection Policy governs the use and storage of your data.

NinjaTrader is a Controller of the personal data you (data subject) provide us. We collect the following types of personal data from you:

• Name
• Address
• Email Address
• Phone Number
• Social Security Number
• Assets Information

NinjaTrader might combine the information you submit with information we receive from business partners and other companies to improve the quality of our products and services. NinjaTrader also may also collect information about your transactions. NinjaTrader depends on its users to update and correct their personal information when necessary.

Important Notice: NinjaTrader records all phone calls for internal use only - for coaching, training, and other purposes. Those recordings are not shared with anyone outside the company except as permitted by law.

3. Why we need it

We need your personal data to provide you with the following services:

• Introduce accounts
• Provide access to use NinjaTrader software
• Operate and improve our products, web sites and services
• Display customized content and advertising
• Performing auditing
• Research and analysis to improve our products, services and websites
• Ease in navigating our websites or services by eliminating the need to repeatedly enter the same information
• Protecting the rights and property of NinjaTrader or our users
• Ensuring functionality of our website
• To develop new services
• To communicate with you

4. What we do with it

Your personal data is processed in Chicago, IL located in the United States. Hosting and storage of your data is done at Amazon Web Services, which is located in the United States.

No third-party providers have access to your data, unless specifically required by law.

5. How long we keep it

Under U.S. Commodity Futures Trading Commission (“CFTC”) regulation, we are required to keep regulatory records, including your personal data, for a specified time period. After this period, your personal data may be irreversibly destroyed. Any personal data we hold for marketing and service update notifications will be kept by us until such time that you notify us to stop sending that information.

6. How we protect it

We process personal information for the purposes for which it was collected and in accordance with this Privacy Policy. We review our data collection, storage and processing practices to ensure that we only collect, store and process the personal information needed in connection with the uses set out in this Privacy Policy. NinjaTrader uses physical, electronic and procedural safeguards and technologies to protect personal information from unauthorized access, use or disclosure. In addition, we protect you and NinjaTrader from unauthorized access, alteration, disclosure, or destruction of information we hold by:

• Using encryption where applicable to keep your data private during transit and while at rest
• Limiting access to your personal information to our employees, contractors and agents who we believe reasonably need to gain access to such information in order to do their jobs to operate, implement, develop, perform or improve our services
• Individuals accessing your information are bound by confidentiality obligations to NinjaTrader and may be subject to termination or legal actions if they fail to comply with these obligations

7. How we share it

NinjaTrader does not share, sell, or rent personal information about you with other individuals or non-affiliated companies except in the following limited circumstances:

• We believe that access, use, disclosure or preservation of personal information is necessary to respond to satisfy any applicable law or statute, regulation, legal process, government request, to establish or exercise our legal rights or to defend against legal claims concerning NinjaTrader, its users, or the public as required or permitted by law.
• We believe the access, use, disclosure or preservation of personal information is necessary to share information to detect, prevent, investigate, or otherwise take action to address fraud, illegal activities, potential threats to the rights, property or safety of any persons.
• We received your consent.
• We provide personal information to our subsidiaries, affiliated companies or other trusted businesses or persons for the purpose of helping NinjaTrader based on our instructions and in compliance with our policies. When NinjaTrader cannot directly provide services based on geographic or regulatory limitations, your personal information may be shared with additional brokerage partners.
• We provide personal information about you if some or all of NinjaTrader assets is transferred in a merger, acquisition or any form of sale, to another company.

8. How we use Cookies

When you visit our website, NinjaTrader sends one or more “cookies” to your computer or other device that uniquely identifies your browser, including your internet protocol address, cookie information, software and hardware attributes, and the page you request. A cookie is a small text file that is placed on your hard disk by a web server. Cookies help us keep a record of your preferences and other information on your computer to save time from repeatedly entering the same information on your later visits to our website. We use cookies to customize the content and advertising, to improve our services; to conduct research, audit, and analysis in order to improve and maintain our services; to develop new services; to protect rights of NinjaTrader and its business partners and our users; to track users trends; and to contact you. NinjaTrader may set and access NinjaTrader’s cookies on your computer. NinjaTrader permits our business partners and other companies to display advertisements on our web pages set and access their cookies on your computer. The business partners’ and other companies’ use of their cookies is subject to their own privacy policies. We do not exercise control over the websites of our business partners or other companies. You have the choice to accept or decline cookies. Most browsers are automatically set up to accept cookies, but you may modify your browser setting to decline all cookies or delete cookies from your browser. Some NinjaTrader features and services and some advertising preferences may not function if your cookies are disabled.

9. What are your rights?

Should you believe that any of your personal data we hold is incorrect or incomplete, you have the ability to request to view this information, correct it or have it deleted. NinjaTrader is obligated by applicable law and regulation and in accordance with our Data Retention Policy to maintain certain records for an extended period of time, generally five years. Data will only be deleted when no conflict with regulation or the Data Retention Policy exists. Please contact us through the Data Subject Access Request Form.

In the event that you wish to complain about how we have handled your personal data, please contact our Data Security Manager in writing at [mailing address]. Our Data Security Manager will then look into your complaint and work with you to resolve the matter.

10. How we update this Policy

NinjaTrader regularly reviews its Privacy Policy. We update this Privacy Policy from time to time, with or without notice. NinjaTrader will, however, notify you of any significant changes by email to your primary email address or by placing notice on our website. Please feel free to contact us via our website if you have questions or suggestions regarding this Privacy Policy.