This supplement to NinjaTrader Group LLC’s and its affiliates, NinjaTrader Clearing LLC (DBA Tradovate), NinjaTrader Brokerage LLC and NinjaTrader LLC (“NinjaTrader” “us” and “we”) NinjaTrader’s Privacy Policy is applicable to you if you are a resident of the State of California. It is intended to help ensure we comply with the California Consumer Protection Act of 2018 (CCPA). You should read this supplemental policy after you have carefully read our primary privacy policy.
NOTICE
California defines personal information as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.” For a variety of reasons, NinjaTrader collects personal information on its website users, account applicants, account owners, and users of our technology and services.
Categories of personal information that we collect
California categorizes personal information into 11 types and NinjaTrader collects 7 of those types (some may overlap):
- Identifiers - name, postal address, online identifier, email address, internet protocol address, account name, drivers license number, date of birth, social security number and tax Ids, passport numbers and other similar identifiers.
- Personal Information as listed in the California Consumer Records Statute - name, signature, telephone number, passport, state identification and driver’s license number, education, employment, banking account and debit card numbers and other financial information.
- Internet or other related network activity - Browsing history, interactions with our website and marketing material and search history, use of our trading platforms and electronic services.
- Geolocation data - physical locations and movements.
- Sensory data - electronic, audio, visual, and other similar information.
- Professional or employment related data - current and past job history or background screening related information.
- Commercial Information - services purchased or considered.
NinjaTrader does not collect:
- Non-public educational information
- Protected Class characteristics under federal or California law - (i.e. age 40 years and older, sex, gender identification, and veteran status among others).
- Biometric information - genetic, physiological and biological behaviors or other identifying information like fingerprints and voiceprints.
- Inferences drawn from other personal information - profile reflecting preferences, characteristics, habits, predispositions, behavior, intelligence, and aptitude.
How we collect Personal information:
Your personal information may be collected in a variety of ways.
Direct Interaction - In this case you voluntarily provide us your personal information by completing account application forms, via phone calls, or by sending us documents both electronic means including via email or regular post. This is generally information you provide when subscribing for or purchasing products, create an account, respond to queries, or request material or information from us.
Automated Collection - As you use our website or trading platforms and through our use of cookies, we may automatically collect data about you, including the Technical Information described above as well as web browsing statistics and patterns.
Third parties and public information - We may receive information about you from third parties such as credit reporting agencies, background check providers, payment agents, and Introducing brokers. Technical data analysis firms like Google may also provide us with personal data regarding you.
Use, Sharing and Disclosure of Your Information
Again, NinjaTrader will not sell your PII. NinjaTrader may however share your PII amongst its affiliates, service providers, futures exchanges, government agencies and courts for the following reasons:
- To review your account application (including credit and background checks) and provide you with access to NinjaTrader service and software.
- To operate, research and improve our services and websites.
- To display customized content and advertisements.
- To perform audits.
- To ensure and improve the functionality of our website and services.
- To develop new services.
- To communicate with you.
- To complete any transactions you may perform through or with us, including processing of orders and emailing statements.
- In connection with mergers acquisitions or restructuring, transfer or sale of all or a portion of our business.
- As described to you when collecting your personal information or as otherwise set forth in the CCPA
Categories of third-party recipients
Each of the following can may each category of personal information that we collect from you:
- Affiliates and subsidiaries of NinjaTrader
- Government Agencies
- Exchanges and outside companies in connection with required reporting
- Third-party service providers that support operations, clearing, execution, and our legitimate business purposed and operations.
- Courts and attorneys in support of bona-fide legal requests
Aside from the above, as part of being a regulated financial institution we are subject various laws and regulations that may require us to disclose your PII to government authorities and exchanges upon which you trade. For example, large trader reporting as well as in compliance with USA Patriot Act requirements. Court orders and Subpoenas may require such disclosure as well.Under the Commodity Futures Commission regulations, we are required to keep your information at a minimum of five (5) years and we may also preserve such information in order to satisfy other governmental or regulatory agency requests, bonafide legal requests, or to defend NinjaTrader against legal claims.
Your specific rights and duty
Requests: You have the right to know what we disclose about you. You can request information related to the collection and use of your personal information for the last 12 months. This can include information related to the categories of information we have collected and sources, as well as our business purpose for such collection, the categories of information disclosed about you including that disclosed to third-parties. Finally, can initiate a data portability request asking for the specific bits of information we collected about you.
Deletion/Correction
You have the right and duty to correct and update your information. NinjaTrader relies upon your information and material changes to, information such as your name, tax ID, contact information, financial condition, employment status are extremely important to us. Your contractual customer agreement requires that you provide updated information if your personal information changes. We are also happy to correct erroneous personal information. Confirmation of corrections may take a short time to evaluate or investigate.
You have the right to request that we delete your personal information. Such requests will be reviewed to determine if an exception to deletion exists. Some of the exceptions that may require or allow us to retain your personal information are: 1. Comply with a legal or regulatory obligation, 2. Enforce security of our systems and network, detect security breaches, and prevent fraud, deception or otherwise illegal activity, 3. To complete the transactions or provide services that you requested and for which we collected the personal information for, or otherwise perform our contract with you, 4. Repair systems or debug products, and 5. Exercise or protect free speech.
To exercise any of your rights, please use the contact information below, we will attempt to respond within 10 days with a confirmation of receipt and then may take up to 45 days to complete the request. We can only respond to request from you or an authorized agent and we will need to confirm the identity of the sender of the request, so please provide enough information to allow us to verify the request, as well as any details of what you are requesting to [email protected]
Non-discrimination rights - we will not charge you more for our services or unless allowed by the CCPA, we will not deny you services for exercising these rights.
CHANGES
NinjaTrader reserves the right to change this policy at any time. Any changes will be effective upon our posting of revised policy or other means, if any, of delivery to you (such as email, or along with statements, or through your client portal). Your continued use of the NinjaTrader website, products and services following the posting of ay changes will serve as acknowledgement and consent to the revised privacy policy.
Questions or Comments?
We are happy to try to respond to inquiries related to this policy. If you have any questions on the data we collect, how, why and with whom we may share it, please submit your questions to [email protected]