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Privacy Policy

Last modified: 10 March 2016

Introduction 

Thalēs Trading Solutions LLC and Thalēs Capital Partners LLC (”Company”, “We”, or “Thalēs”) respects your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit our offices, email our associates, or visit the website thales.com (our ”Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information. By opening an account with Thalēs or by using the products and services available through Thalēs, you have consented to the collection and use of your personal information in accordance with the privacy policy set forth below.

 

This policy applies to information we collect:

  • In person.
  • On the Website.
  • In e-mail, text and other electronic messages between you and this Website.
  • By us offline or through any other means, including on any other website or online platform operated by Company or any third party (including our affiliates and subsidiaries); or
  • By any third party (including our affiliates and subsidiaries), including through any application or content that may link to or be accessible from or on the Website

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. This policy may change from time to time (see Changes to Our Privacy Policy below). Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

 

Children Under the Age of 13 

Our Website is not intended for children under 13 years of age. No one under age 13 may provide any personal information to the Website. We do not knowingly collect personal information from children under 13. If you are under 13, do not use or provide any information on this Website or on or through any of its features.

 

Information We Collect About You and How We Collect It 

We collect several types of information from and about our users, including information:

  • by which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number or any other identifier by which you may be contacted online or offline (”personal information”);
  • that is about you but individually does not identify you, such as trading data we collect form our brokerage partners; and/or
  • about your internet connection, the equipment you use to access our Website and usage details.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses and information collected through cookies, web beacons and other tracking technologies.
  • From third parties, for example, our business partners.

    Information You Provide to Us

  • The information we collect on or through our Website and in person may include:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our Website.

    The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons. Pages of our the Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs. pixel tags and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).

     How We Use Your Information 

    We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To provide you with information, products or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account/subscription, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our Website or any products or services we offer or provide though it.
  • In any other way we may describe when you provide the information.
  • For any other purpose with your consent.

    Disclosure of Your Information 

    We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

     We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our subsidiaries and affiliates.
  • To contractors, service providers and other third parties we use to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution or other sale or transfer of some or all of Thalēs’, whether as a going concern or as part of bankruptcy, liquidation or similar proceeding, in which personal information held by Thalēs  about our Website users is among the assets transferred.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

    We may also disclose your personal information:

  • To comply with any court order, law or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our terms of use and other agreements, including for billing and collection purposes.
  • If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of Thalēs, our customers or others.
  • Information that you provide to us for opening an account.
  • Information that you provide by filling in forms on our Website. This includes information provided at the time of registering to use our Website, subscribing to our service, or requesting further services. We may also ask you for information when you report a problem with our Website.
  • Records and copies of your correspondence (including e-mail addresses), if you contact us.

    Information We Collect through Automatic Data Collection Technologies.

     

    As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:

    • Details of your visits to our Website, including traffic data, location data, logs and other communication data and the resources that you access and use on the Website.
    • Information about your computer and internet connection, including your IP address, operating system and browser type.

      The information we collect automatically is statistical data and may include personal information, or we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

Your California Privacy Rights 

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to info@thales .com or write us at:          

Thalēs
Attention:  California Privacy Inquiries
410 Park Avenue
Suite 420
New York, NY  10022

Data Security 

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration and disclosure. In addition to our strong password and authentication policies, Thalēs has implemented multiple layers of security to its systems, including up-to-date anti-virus and anti-malware software. All information you provide to us is stored on our secure servers behind firewalls.

We have also implemented a Data Breach Plan for recognizing and responding to data breaches. In the event of a data breach, we will initiate the notification procedures required by the Data Breach Plan.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Website. The information you share in public areas may be viewed by any user of the Website.

Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy 

 It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this privacy policy to check for any changes.

Contact Information 

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Thalēs
Attention:  Privacy Inquiries
410 Park Avenue
Suite 420
New York, NY 10022