COMMODITIES UNIVERSITY PRIVACY POLICY
December 19th, 2019
For EU countries, please review our EU privacy notice.
Commodities University and OTA Franchise Corporation (collectively referred to as “Commodities University”) understands that you care about how we collect, use, and share information. This Privacy applies to Commodities University and our websites, mobile applications, social media sites and handles, and emails we send, as well as the information we collect when you interact with us through social media, email, and other online services (collectively our “Services”). This Privacy Policy explains:
This applies anywhere it is linked by us. It does not apply to non-Commodities University websites and mobile applications that may link to the Services or be linked to or from the Services; please review the privacy policies on those websites and applications directly to understand their privacy practices.
Information We Collect
Information you give us: Some of the Services may include features or services that permit you to enter contact information and other information about you. We collect and store any information you enter on our Services. This includes:
• Contact information when registering to use our Services.
• Payment information and associated contact information when engaging in a transaction on our site.
• Email address information when subscribing to our email bulletins.
• Any information or data you provide by interacting in our online forums and chatrooms, or by commenting on content posted on our Services. Please note that these comments are also visible to other users of our Services
• Information you provide when you complete a survey administered by us or a service provider acting on our behalf.
• Information you may submit to inquire about or apply for a job with us.
• If you contact us, we may keep a record of that correspondence and any contact information provided.
• Information regarding your participation in trainings/ educational classes.
• Your image, voice prints, olfactory, and similar information when you participate in any of our recordings and videos.
Information We Collect Automatically: When you interact with the Services, certain information about your use of our Services is automatically collected. Much of this information is collected through cookies, web beacons, and other tracking technologies, as well as through your web browser or device. This includes:
• Details of your visits to our site and information generated in the course of the use of our site (including the timing, frequency and pattern of service use) including, but not limited to, traffic data, location data, weblogs and other communication data, the resources that you access, and how you reached our site.
• Details regarding the device you use to access our Services, including, but not limited to, your IP address, operating system and browser type.
• Information about how you interact with our ads and newsletters, including whether you open or click links in any correspondence.
Please see below for more information about how our automatic collection of information works.
Additional Information About Our Use of Tracking Technologies and Interest-Based Advertising
Commodities University relies on partners to provide many features of our sites and services using data about your use of Commodities University and other sites. We use cookies for the following purposes:
• Site Operations: Enabling features that are necessary for providing you the services on our site, such as identifying you as being signed in, tracking content views, remembering your preferences and the number of times you have been shown an advertisement.
• Analytics: Allowing us to understand how our services are being used, track site performance and make improvements.
• Personalized Advertising: Delivering tailored advertising based on your preferences or interests across services and devices and measuring the effectiveness of the ads.
• Social Media: Enabling the sharing of content from our services through social networking and other sites.
Below is a list of these partners with links to more information about their use of your data and how to exercise your options regarding tracking.
Most web browsers automatically accept cookies but, if you prefer, you can usually modify your browser setting to disable or reject cookies. If you delete your cookies or if you set your browser to decline cookies, some features of the Services may not be available, work, or work as designed. You may also be able to opt out of or block tracking by interacting directly with the third-parties who conduct tracking through our Services.
Please note that opting-out of advertising networks services does not mean that you will not receive advertising while using our Services or on other websites, nor will it prevent the receipt of interest-based advertising from third parties that do not participate in these programs. It will, however, exclude you from interest-based advertising conducted through participating networks, as provided by their policies and choice mechanisms. If you delete your cookies, you may also delete your opt-out preferences.
How We Use and Protect Your Information
We may use the information we collect from you for the following purposes:
• To provide you with our products and services, including to take steps to enter into a contract for sale or for services, process payments, fulfill orders, and send service communications.
• To enable additional features on our Services and to provide you with a personalized service.
• To provide you with the best service and improve and grow our business, including understanding our customer base and purchasing trends and understanding the effectiveness of our marketing.
• To detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and to comply with legal requirements regarding the provision of products and services.
How We Secure the Information We Collect from or About You
We use a combination of physical, technical, and administrative safeguards to protect the information we collect through the Services. While we use these precautions to safeguard your information, we cannot guarantee the security of the networks, systems, servers, devices, and databases we operate or that are operated on our behalf.
Our Sharing of Your Information
• Service Providers: We engage vendors to perform functions on our behalf such as: website, software, and data storage, content management, database management, technical integration, marketing automation, analytics, site optimization, conducting customer surveys, and payment processing.
• Social Media Platforms: Where you choose to interact with us through social media, your interaction with these programs typically allows the social media company to collect some information about you through digital cookies they place on your device and other tracking mechanisms. In some cases, the social media company may recognize you through its digital cookies even when you do not interact with their application. Please visit the social media companies’ respective privacy policies to better understand their data collection practices and controls they make available to you.
• Third parties involved in advertising: We partner with third parties who assist us in serving advertising regarding the Services to others who may be interested in the Services. We also partner with third parties who use cookies to display interest-based advertising to you on the Services. These third parties may use tracking technologies on our website to collect or receive information from the Services and elsewhere on the internet and use that information to provide measurement services and target ads. While Commodities University will not share information that identifies you by name with unaffiliated third parties for their own uses, such third parties may, with application. Please visit the social media companies’ respective privacy policies to better understand their data collection practices and controls they make available to you.
• Third parties involved in advertising: We partner with third parties who assist us in serving advertising regarding the Services to others who may be interested in the Services. We also partner with third parties who use cookies to display interest-based advertising to you on the Services. These third parties may use tracking technologies on our website to collect or receive information from the Services and elsewhere on the internet and use that information to provide measurement services and target ads. While Commodities University will not share information that identifies you by name with unaffiliated third parties for their own uses, such third parties may, with sufficient data from other sources, be able to personally identify you
Additional Information About our Data Collection and Sharing Practices
Sharing of Aggregated Data: We may analyze aggregated, de-identified data and share these analyses at our discretion, including with marketing agencies, media agencies and analytics providers. These third parties will not be able to relate this data to identifiable individuals.
Combination of Information: We may combine information from the Services together and with other information we obtain from our business records.
Personal Data Collected From You About Others: If you decide to invite others to the Site, we will collect your and the other person’s names, e-mail addresses, and/or phone numbers in order to send an e-mail or text message and follow up with the other person. You hereby agree that you will obtain the other person’s consent to this before giving us their personal data. You hereby agree not to send us the contact details of any legal minor. We will inform any other person you invite that you gave us his or her details in the invitation e-mail.
Change of Ownership or Corporate Organization: We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We cannot promise that an acquiring party or the merged entity will have the same privacy practices or treat your information the same as described in this Policy.
Cross-border Transfer of Data: If you use our Services outside of the United States, you understand that we may collect, process, and store your personal information in the United States and other countries. The laws in the U.S. regarding personal information may be different from the laws of your state or country. Any such transfers will comply with safeguards as required by relevant law. By using the Services, you consent to the collection, international transfer, storage, and processing of your data.
Your Options and Rights
If at any time you would like to unsubscribe from receiving future emails, you can click the unsubscribe link at the bottom of any email bulletin, or email us at privacy@commoditiesuniversity.com and we will promptly remove you from all correspondence. You may opt-out of sharing by changing the settings on your account profile.
Your California Privacy Rights
Persons with disabilities may obtain this notice in alternative format upon request by contacting us at privacy@commoditiesuniversity.com or calling (866) 939-4958.
California Shine the Light: Residents of the State of California have the right to request information from us regarding other companies to whom the company has disclosed certain categories of information during the preceding year for the other companies’ direct marketing purposes. If you are a California resident and would like to make such a request, please contact us at:
Commodities University Corporate Headquarters
17780 Fitch
Suite 200
Irvine, CA 92614
(866) 939-4958 or 011-949-608-7424
Email: privacy@tradingacademy.com
California Consumer Privacy Act:
The California Consumer Privacy Act (“CCPA”) provides California residents with rights to receive certain disclosures regarding the collection, use, and sharing of “Personal Information,” as well as rights to know/access, delete, and limit sharing of Personal Information. The CCPA defines “Personal Information” to mean “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.” Certain information we collect may be exempt from the CCPA because it is considered public information (i.e., it is made available by a government entity) or covered by a specific federal privacy law, such as the Gramm–Leach–Bliley Act, the Health Insurance Portability and Accountability Act, or the Fair Credit Reporting Act.
To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below.
Right to Notice at Collection Regarding the Categories of Personal Information Collected
You have the right to receive notice of the categories of Personal Information we collect, and the purposes for which those categories of Personal Information will be used. This notice should be provided at or before the time of collection. The categories we use to describe the information are those enumerated in the CCPA.
• Personal Identifiers:
o We collect your name, phone number, and email address and contact address when you create an account or complete a transaction. If you choose to create an account, you will also be asked to create a username, and we will assign one or more unique identifiers to your profile.
o You provide us with payment information, which may be your credit card number or a bank account (if you pay by check), when you complete a transaction.
o You have the option to store this information to your account or set up a recurring transaction.
o We do not collect your Social Security number, Driver’s License number, or Passport number.
o We do not collect any medical information or health information about you.
o We collect your IP address automatically when you use our Services.
o We collect your Device ID automatically when you use our services.
o We also collect information about your spouse and/or partner.
• Protected Classifications: We do not collect your gender, racial or ethnic origin, or sexual orientation.
• Commercial Information: When you engage in transactions with us, we create records of goods or services purchased or considered, or purchasing or consuming histories or tendencies.
• Biometric Information: We do not collect information about your physiological, biological, or behavioral characteristics.
• Internet or Other Electronic Network Activity Information: We collect information about your browsing history, search history, information regarding your interaction with websites, and applications or advertisements automatically when you utilize our Services.
• Geolocation Data: We do not collect your precise location (e.g., your GPS coordinates).
• Audio, electronic, visual, thermal, olfactory, or similar information: If you contact us via phone, we may record the call. We will notify you if a call is being recorded at the beginning of the call. We collect your image, voice print and olfactory similar information if you are recorded in a classroom setting during one of our trainings or educational courses.
• Professional or employment-related information: We collect information about your current employer and your employment history if you are a job applicant. A copy of our employee privacy notice will be made available to you during the application process.
• Education information: We collect information about the institutions you have attended and the level of education you have attained. If you are a job applicant, a copy of our employee privacy notice will be made available to you during the application process.
• Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We may analyze your actual preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile.
We may use any of the categories of information listed above for other business or operational purposes compatible with the context in which the Personal Information was collected.
We may share any of the above-listed information with Service Providers, which are companies that we engage for business purposes to conduct activities on our behalf. Service Providers are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of Service Providers with whom we share information and the services they provide are described in this Privacy Policy.
Right to Know About Personal Information Collected, Disclosed, or Sold.
You have the right to request that we disclose to you the Personal Information we collect, use, disclosure, or sell. In order to process your request to know/access your Personal Information or delete your Personal Information we may ask you to take additional steps to verify your request or identity.
Verification Procedures
In order to process your request to know about or delete personal information we collect, disclose, or sell, we must verify your request. We do this by:
• Providing personal identifiers we can match against information we may have collected from you previously; and
• Asking you to confirm your request using the email or telephone account stated in the request; and
If you have authorized someone else to make requests on your behalf, we may require that you provide notarized statements confirming the identity and authority of that person.
Right to Know/Access Information
You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request.
Right to Request Deletion of Information
You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you. To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Right to Information Regarding Participation in Data Sharing for Financial Incentives
You have the right to be free from discrimination based on your exercise of your CCPA rights. We may run promotions from time to time whereby we incentivize a consumer to share certain pieces of information with us; for example, we may offer a one-time discount if consumers sign up for our email marketing list. Participation in these incentives is voluntary, and you may opt out of the data sharing at any time.
Right to Opt Out of Sale of Personal Information to Third Parties
We also sell some personal information to third parties. A company may be considered a third party either because the purpose of sharing is not an enumerated business purpose under California law, or because our contract does not restrict them from using Personal Information for other purposes.
We sell the following information to third parties:
• Personal Identifiers:
o We provide your contact information to directory services providers and public safety authorities.
o We provide your IP address and Device ID to our advertising partners, Corporate Affiliates, and business partners.
o All personal information may be shared with our Corporate Affiliates.
We may also disclose information to other external parties who are not listed here when required by law or to protect our Company or other persons, as described in our Privacy Policy.
Please note that your right to opt out does not apply to our sharing of personal information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal information only for that function.
We may also disclose information to other entities who are not listed here when required by law or to protect our Company or other persons, as described in our Privacy Policy.
Special Information for Nevada Residents
Residents of the State of Nevada have the right to opt out of the sale of certain pieces of their information to third parties who will sell or license their information to others. At this time, Commodities University does not engage in such sales. If you are a Nevada resident and would like more information about our data sharing practices, please email privacy@commoditiesuniversity.com
Information for Individuals Located in the EU and Switzerland
We process personal data on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedom related to data privacy. Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities, as described above.
Users that reside in the EEA or Switzerland have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available.
If you are a resident of the EEA or Switzerland, you are entitled to certain rights. Please note: In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you. These rights include the ability:
• to request from us access to personal information held about you
• to ask for the information we hold about you to be rectified if it is inaccurate or incomplete;
• to ask for data to be erased if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.
• to request that we restrict our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.
To submit a request to exercise your rights, please contact us at privacy@commoditiesuniversity.com
We may have a reason under the law why we do not have to respond to your request, or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Changes to This Policy
We may make changes to this Policy from time to time. We will post any changes, and such changes will become effective when they are posted. Your profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.
To submit a request to exercise your rights, please contact us at privacy@commoditiesuniversity.com
We may have a reason under the law why we do not have to respond to your request, or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
Changes to This Policy
We may make changes to this Policy from time to time. We will post any changes, and such changes will become effective when they are posted. Your continued use of our Services following the posting of any changes will mean you accept those changes.
For questions about our privacy practices, contact us at:
Commodities University Corporate Headquarters
4607 Lakeview Canyon Road
Suite 398
Westlake Village, CA 91361
Email: privacy@commoditiesuniversity.com