Last Updated: November 11, 2024
OnTrade (“OnTrade Inc,” “we,” “our,” and/or “us”) values the privacy of individuals who use our application, websites, and related services (collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose information from users of our Services (“Users”). For information about how we collect, use, share, and otherwise process your personal information as a financial institution, please refer to our GLBA Privacy Notice. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.
Information We Collect
We may collect a variety of information from or about you or your devices from various sources, as described below.
A. Information You Provide to Us.
Registration Information. If you join our waitlist or are referred by a friend, we ask you for your email address. If you are approved from the waitlist or receive an email based on a referral, you will receive a unique invitation code in order to create your account. When you sign up for an account, we ask you for your name, email address, phone number, mailing address, username, and profile photo. If you sign up using a Google account, we will also receive information from Google such as your first name, last name, email address, mailing address, language preference, and profile photo.
Account Information. After you register to use our Service, we ask you for your company email and information about your investments, such as the total amount of your restricted stock units and the amount of your restricted stock units that have vested, the grant date and schedule of your restricted stock units, the vesting date and schedule of your restricted stock units, and photo or document proof of your investments.
Communications. If you contact us directly, we may receive additional information about you, such as your name, email address, and the contents of a message or attachments that you may send to us, and other information you choose to provide. When you communicate with us online, third party vendors receive and store these communications on our behalf. If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. When we send you emails, we may use embedded pixels or other technologies to track information about your receipt and interaction with our emails, such as whether and when you open them, whether you access any links included in our emails, how long you read our emails, whether you forward our emails and to whom, your Location Information (described below), and your Device Information (described below), to learn how to deliver a better customer experience and improve our Services.
Payment Information. If you make a payment on our Services, your payment-related information, such as credit card or other financial information, is collected by our third-party payment processor on our behalf.
User Feedback. We appreciate feedback, including ideas and suggestions for improvement or rating an Output in response to an Input ("Feedback"). If you rate an Output in response to an Input—for example, by using the thumbs up or upvote/thumbs down or downvote icons—we will store the related conversation as part of your Feedback.
B. Information We Collect When You Use Our Services.
Location Information. When you use our Services, we receive your location information. For example we infer your location information by using your internet protocol (IP) address.
Device Information. We receive information about the device and software you use to access our Services, including IP address, device type, device identifiers, web browser type and version, operating system version, phone carrier and manufacturer, application installations, mobile advertising identifiers, and push notification tokens.
User Content. You may choose to submit questions to the Service to ask about investment-related information.
Investment Questionnaire. Users of our Services may fill out an investment strategy questionnaire to get personalized guidance about financial considerations related to their restricted stock unit success, pricing, market exposure, and capital gains. We will collect your answers to a number of questions about your risk tolerance, cash needed from your restricted stock units, percentage of vested restricted stock units, and how long you have held vested restricted stock units.
Usage Information. We automatically receive information about your interactions with our Services, like the pages or other content you view, referrer information (the website you visited before coming to our Services), the dates and times of your visits, your answers to questionnaires, your comments, and any content you post.
Prompts and Outputs. Our Services allow you to submit text, user responses, your answers to questionnaires and surveys, feedback, and other materials to the Services (“Prompts”), which generate responses based on your Prompts (“Outputs”). We will collect any information you choose to provide in your Prompts and this information may be reproduced in the Outputs.
Information from Cookies and Other Tracking Technologies. We and our third-party partners collect information about your activities on our Services using cookies, pixel tags, SDKs, or other tracking technologies. Our third-party partners, such as analytics, advertising, and security partners, may also use these technologies to collect information about your online activities over time and across different services.
C. Information We Receive from Other Sources.
Information from Third-party Services. If you choose to link our Services to a third-party account, we may receive information about you, including your name, email, address, language preferences, profile photo, and your use of the third-party account. If you wish to limit the information available to us, you should visit the privacy settings of your third-party accounts to learn about your options.
Information from Third-Party Sites. We collect publicly-available information from third-party sites to enable the training of our models and systems.
How We Use the Information We Collect
We use the information we collect:
To provide, maintain, improve, and enhance our Services;
To train, develop, and improve the artificial intelligence, machine learning, and models that we use to support our Services;
To personalize your experience on our Services such as by providing tailored content and recommendations;
To understand and analyze how you use our Services and develop new products, services, features, and functionality;
To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
To facilitate the connection of third-party services or applications, such as to provide you access to news;
To generate anonymized or aggregate data containing only de-identified, non-personal information that we may use for any lawful purposes such as to publish reports;
To send you text messages and push notifications;
To facilitate transactions and payments;
To find and prevent fraud and abuse, and respond to trust and safety issues that may arise;
For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
For other purposes for which we provide specific notice at the time the information is collected.
How We Disclose the Information We Collect
Vendors and Service Providers. We may disclose any information we receive to vendors and service providers retained in connection with the provision of our Services.
User Content. Users can use our Services to find, enjoy, and share content. For any of the posts or comments you submit to OnTrade and OnTrade makes public in the community forums, your username may be viewable by other users. In the “Your Choices” section of this Privacy Policy, we describe the controls that you can use, along with other relevant settings associated with your account, to limit the sharing of certain information. The content you post to the Services will be displayed on the Services and viewable by other users. We are not responsible for the other users’ use of available information, so you should carefully consider whether and what to post or how you identify yourself on the Services.
Social Networks and Other Online Services. Our Services allow you to, upon your direction, disclose information to social networking services, such as X, Facebook, Slack, Reddit, and Instagram. You understand and agree that the use of your information by any social networking websites will be governed by the privacy policies of these third-party platforms and your settings on that platform. We encourage you to review their privacy policies.
AI Service Providers. We may disclose information we receive to vendors that provide artificial intelligence services that provide backend support for our Services.
Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. You can learn more about Google’s practices by visiting https://www.google.com/policies/privacy/partners/.
Advertising Partners. We work with third-party advertising partners to collect and process your information in order to show you ads that we think may interest you. Some of our advertising partners are members of the Network Advertising Initiative (https://optout.networkadvertising.org) or the Digital Advertising Alliance (https://optout.aboutads.info) and serve ads through cookie-based technologies. Please visit their opt-out pages to learn about how you may opt out of receiving certain web-based personalized ads from member companies. These opt-outs will apply only to our third-party advertising partners that are members of these organizations. These opt-outs will not apply when our partners serve ads through non-cookie based technologies. You can access any settings offered by your mobile operating system to limit ad tracking, or you can install the AppChoices mobile app to learn more about how you may opt out of personalized ads in mobile apps.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.
Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.
Consent. We may also disclose your information with your permission.
Your Choices
Sharing Preferences.
We provide you with settings to allow you to set your sharing preferences for content you post to the Services.
To change whether certain information is publicly viewable, you can adjust the settings in the form of each question you submit.
Text Messages. If you wish to opt out of marketing text (SMS) messages from OnTrade, you can email [email protected] or text the word “STOP” to the number from which you are receiving the messages. If you wish to opt out of all text messages from OnTrade, you can email [email protected] or text the word “STOP” to the number from which you are receiving the messages, however you acknowledge that opting out of receiving all messages may impact your use of the service. You may continue to receive text messages for a short period while we process your request, including a message confirming the receipt of your opt-out request.
Third Parties
Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.
Security
We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, because no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.
Children’s Privacy
We do not knowingly collect, maintain, or use personal information from children under 18 years of age, and no part of our Service(s) is directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at [email protected].
International Visitors
Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the U.S. for storage and processing. We may also transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.
Update Your Information
You can update your account and profile information or close your account through your profile settings.
Changes to this Privacy Policy
We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or disclose personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.
Contact Information
If you have any questions, comments, or concerns about our processing activities, please email us at [email protected].