Privacy Policy of ToriTrades LLC

This Privacy Policy (“Policy”) of ToriTrades LLC, and all related content, materials, and services (collectively, the “Site”) is hereby made effective as of September 17, 2021, by Tori Trades LLC (“Tori Trades” or "ToriTrades" or “we” or “us” or “our”).

General

When you (“you” or “your” or “user” or “member”) browse the Site, register for a membership, or use our products, services, or other materials available on the Site, you will provide certain information to us and we will learn, collect, use and share certain information about you for various purposes, as more fully set forth in this Policy.

By using or accessing the Site, you agree that you have read and understood this Policy and acknowledge and consent to the learning, collection, use, and sharing of your information as described in this Policy. If you do not agree with any portion of this Policy, you are prohibited from using or accessing the Site.

Information We Collect and Use

Our primary purpose in collecting information about you is to provide you with our products and services, but we will also use this information in connection with the operation and improvement of the Site and our business and may provide this information to our affiliates or to other third parties for use in their businesses or for other purposes.

When you access, visit. register for and otherwise use the Site, we will learn, collect, store and use:

personally identifiable data and information about you, such as your name, physical and/or electronic mail address, telephone, fax or mobile numbers, and other data or information that can be used to specifically identify you (all such personal data and information is collectively referred to herein as, “Personal Information”); and
non-personally identifiable information about you, such as demographic information, location, age, gender, and data on your use of the Site and other online activity (“Non-Personally Identifiable Information”).

Personal Information and Non-Personally Identifiable Information are together referred to herein as “Information”.

Using the Site. When you access, visit and use the Site, we automatically receive and store the uniform resource locator of the prior webpage that you were on and of the webpage where you go after you leave the Site. We also receive and store additional information such as your internet protocol (IP) address, browser types, domain name, and other statistical data involving your access, browsing, and use of the Site. This Information is generally collected passively using various technologies, but this information may also be provided by you through interactions or communications with the Site or us.

Registration. In order to become a registered user of the Site or to use or obtain certain products or services offered on or through the Site, we will request, and you will need to provide us with, Personal Information such as your name, postal and/or email address, telephone, fax, age or mobile numbers. Registered users who sign up for any trial membership, premium membership, or other accounts, product, or service must also provide billing and credit card information. Without providing

Personal Information, you cannot create an account, become a registered user of the Site, or obtain our products or services. We will use this information to provide our products and services to you, in connection with our business and operations and in other ways that are provided in this Policy. We may also collect certain other information from you such as demographic information. Providing this information is optional, and is not required.

We may also collect information when you interact with the Site or our customer service in order to assist you or maintain or improve the Site.

Chat Room. We operate a chat room on the Site. Any information you disclose in a chat room becomes public information. If you post Personal Information online, in a chat room, or anywhere on the Site that is accessible to the public or to other users, you have made that information available to the public, and it is no longer private. In that case, other people may receive, collect and use that information. You should exercise caution when deciding whether to post or disclose any of your Personal Information or any other information in any chat room or forum, including any public or private chat room or forum on the Site.

Please note that Personal Information you have published on any chat room or forum, including any chat room or forum on the Site, may remain publicly available even if you request that such information be internally deleted by Tori Trades. We will not post your Personal Information in any public chat rooms or forums.

Cookies and Tracking Technologies

Like many websites, we use cookies and similar technologies to record your preferences, track your usage of the Site, improve the Site and collect data and other information. A browser cookie is a small piece of data that is stored on your device to help websites and mobile apps remember things about you. Other technologies, including Web storage and identifiers associated with your device, may be used for similar purposes. In addition to browser cookies, Tori Trades also receives and collects Information through other commonly used techniques and technologies, including without limitation:

through your browser, computer, mobile device, or tablet to ensure Site functionality,
through pixel tags, web beacons, or clear GIFs,
through Flash objects, or
through your IP Address.

For example, we use programs, software, and/or applications, including, without limitation, Google Analytics, to analyze typical user behavior, improve the Site or in connection with our business or operations; and, for security purposes and to ensure the availability of the Site, we may also use programs, software, and applications to monitor network traffic, identify unauthorized attempts to upload or change information, or otherwise cause damage to the Site or Tori Trades. And, when you visit the Site, we automatically receive and collect the uniform resource locator of the prior webpage that you were on and of the webpage where you go after the Site, the IP address of your computer, the type of operating system, and web browser you are using, your location, date and time of your access, pages viewed on the Site and other information related to your visit to the Site.

How We Use Cookies and Other Tracking Technologies

Like most providers of online services, Tori Trades uses cookies and other tracking technologies for a number of reasons, including, without limitation, protecting your Tori Trades data and account, helping us see which features are most popular, counting visitors to a page, improving our users’ experience, keeping our services secure, and generally providing you with a better, more intuitive, and satisfying experience. Most cookies we use fall into one of the following general categories:

Category of Cookies

Why we use these cookies

Strictly Necessary

These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in, or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work.

Performance

These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. If you do not allow these cookies we will not know when you have visited our site and will not be able to monitor its performance.

Functionality

These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third-party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.

Targeting

There are also certain third-party cookies that reside on our site that collect Personal Information, such as information that uniquely identifies your IP address, browser, and internet device, that may be used by these third parties to, among other things, build a profile of your interests and show you relevant advertisements on this site and/or other sites.

Your Options

Cookies are automatically placed on your computer when you access the Site. Your browser or device may allow you to block or otherwise limit the use of cookies. Cookies are an important part of how our services work, so removing, rejecting, or limiting the use of them could affect the availability and functionality of our services.

Browser Cookies

Your browser may provide you with the option to refuse some or all browser cookies. You may also be able to remove cookies from your browser. For more information about how to manage browser cookies, please follow the instructions provided by your browser.

Information We Do Not Collect

Tori Trades is solely an informational and educational platform and online community, providing impersonal advice and education so you can independently trade your own funds and securities. We do not provide investment advisory services or trade securities for the account of others. We are not an investment adviser or broker-dealer, do not provide advice on the value or advisability of your purchases of securities, and do not effect or facilitate transactions or otherwise handle securities or funds of others.

We only communicate with you through the contact information and social media accounts on the Site would never give you personalized investment advice, and would never ask you for your social security number, to wire money, or to provide access or information on your financial or securities accounts (except for billing purposes as set forth above)! Don’t be fooled by scams or other imposters asking for this information, they are not from Tori Trades! If someone pretending to be affiliated with Tori Trades asks you for this information, please DM https://www.instagram.com/tori.trades

How We Use Your Information

Tori Trades uses your Information, including Personal Information, in connection with the operation, development, and improvement of the Site and other products and services offered by Tori Trades and its affiliates, the operation and billing of your account and/or membership, and for other uses consistent with this Policy. Tori Trades and its affiliates may use your Personal Information for any purpose related to their business or operations, including, without limitation, the following:

to provide our products and services, operate the Site and respond to your inquiries and fulfill your requests,
to manage your account and/or membership, subscription, and other billing purposes,
to allow outside vendors or others to perform services on our behalf,
to inform you about information regarding the Site, products or services for which you apply or may be interested in applying for, or in which you are already enrolled, changes to terms, conditions, and policies and/or other administrative information,
to deliver marketing communications that we believe may be of interest to you, including ads or offers tailored to you from us or our affiliates,
to personalize your experience on the Site,
to verify your identity and/or location in order to allow access to your accounts, and to maintain measures aimed at preventing fraud and protecting the security of the account and Personal Information,
to allow you to participate in surveys and other forms of market research, sweepstakes, contests, and similar promotions and to administer these activities (some of these activities may have additional rules, which may contain additional information about how Personal Information is used and shared),
for general business purposes, to otherwise manage and operate the Site, develop new services and products, and conduct the business and operations of Tori Trades and its affiliates, including data analysis, audits, developing and improving products and services, enhancing the Site, identifying usage trends and determining the effectiveness of promotional campaigns,
for risk control, for fraud detection and prevention,
to enforce the Terms and Conditions of tori-trades.thinkific.com (the “Terms and Conditions”),
to protect the rights and property of Tori Trades or its officers, directors, shareholders, employees or agents, and
to comply with laws and regulations, and to comply with other legal processes and law enforcement requirements.

Please be aware that you are responsible for the payment of any fees or costs incurred by you in connection with the receipt of communications from Tori Trades or its affiliates, including data, internet, cellular carrier, or other similar fees.

Who Your Information May Be Shared With

Tori Trades may share your Personal Information and Non-Personally Identifiable Information with third-party vendors who need to know Information about you in order to provide their services to us. This group includes vendors that help us provide our services to you (like payment processing providers) and those that help us understand and enhance our services (like analytics providers). We may also share your Personal Information:

as described in this Policy;
as required by law or to comply with legal process, including, but not limited to, civil and criminal subpoenas, court orders, or other compulsory disclosures;
as reasonably necessary to respond to claims of a violation of the rights of third parties, whether or not the third party is a user, individual, entity, or government agency;
to detect, prevent and address fraud and other illegal activity and to prevent death or imminent bodily harm; or
for any purpose related to the business or operations of Tori Trades or its affiliates.

Tori Trades may also share or otherwise provide Non-Personally Identifiable Information or other aggregated anonymous data or information to third parties (including sub-processors) about the users or usage of the Site for purposes that we deem, in our sole discretion, to be appropriate.

Tori Trades may post and use any testimonials about the Site that you have provided in connection with the marketing and promotion of the Site.

Testimonials and other marketing, promotions, and advertisements may include limited Personal Information (such as first name and general location) that you have provided to Tori Trades.

Tori Trades may also disclose your information to third parties as part of our selling the stock or assets of the company, as the result of a proposed or actual change in control of the company, or in connection with any financing of or investment in the company by a third party. Any successor or assign of Tori Trades, including any third party to which Tori Trades transfers or sells its assets, will have the right to continue to use your Information.

IF YOU DO NOT AGREE WITH ANY TERM OR PROVISION OF THIS POLICY, PLEASE EXIT THE SITE IMMEDIATELY. PLEASE BE ADVISED THAT YOUR CONTINUED USE OF THIS SITE OR THE PRODUCTS OR INFORMATION PROVIDED THEREBY SHALL INDICATE YOUR CONSENT AND AGREEMENT TO THIS POLICY

Access to and Protection of Your Personal Information. You may access, modify and correct some Personal Information provided to us through your account information on the Site. If you update, modify or correct any such Personal Information, we may keep copies of your Personal Information prior to such update, modification, or correction for uses provided for in this Policy. To the extent that you wish to access, modify or correct Personal Information that is not available through your account information, you may contact us in the manner set forth below. We will endeavor to respond to your request in a timely manner.

Personal Information will be stored by us in databases or servers owned and maintained by us or our affiliates, agents, or service providers. Personal Information will be protected in a commercially reasonable manner. We take what we believe to be industry-standard security measures to help safeguard your Personal Information, but no system is entirely secure. Although we protect your Personal Information in a commercially reasonable manner and with industry-standard security measures, we do not guarantee that your Information will always remain secure.

Data Retention

We process your Personal Information while your account is active or as needed to provide you our services. If you close your account(s), your Personal Information will be retained for seven years from the closure of your account.

Do Not Track

Some web browsers have a “Do Not Track” feature. This feature lets you tell websites you visit that you do not want to have your online activity tracked. These features are not yet uniform across browsers. Our Website is not currently set up to respond to those signals.

Links to Other Websites

We are not responsible for the practices employed by websites linked to or from the Site, nor the information or content contained in such websites, nor any third party’s use of information or other data or information which we have sold, disclosure, shared, or otherwise provided to them. Please remember that when you use a link to go from the Site to another website, this Policy is no longer in effect. Your browsing and interaction on any other website, including those that have a link on the Site, are subject to that website’s rules, terms, and conditions, and/or policies.

Children

The Site is not directed to individuals under the age of 13. Tori Trades does not intentionally collect any Information on the Site from individuals we actually know are under 13. In fact, registration for and use of the Site by persons under the age of 18 is expressly prohibited. If we become aware that we have collected any Information, including without limitation Personal Information, from a person under age 13, we will take steps to remove that information.

Miscellaneous

In addition to the Site, this policy also applies to any Tori Trades mobile applications and any Information that we may collect through such applications.

This Policy has been adopted and is effective as of the date set forth above, without waiving or otherwise releasing any right or obligation under any prior privacy policy or similar document or agreement of Tori Trades, including without limitation any prior privacy policy or similar document or agreement set forth on the Site. This Policy hereby amends and restates any such prior privacy policy.

Tori Trades reserves the right to revise this Policy at any time without notice. By using the Site, you are agreeing to be bound by the then-current version of this Policy, and your continued use of the Site reaffirms your agreement to the then-current Policy. You agree to consult the Site regularly for up-to-date versions and information about this Policy. Without limiting the foregoing, we will provide notification by electronic mail, check box, highlighted text on the Site, or other means we deem adequate, of the adoption of a revised or amended Policy that contains material revisions, amendments, or other changes to the terms.

In the event that the terms of this Policy conflict with or are inconsistent with any provision of the Terms and Conditions, the Terms and Conditions shall govern.

Any claim under this Policy or otherwise related to the Site or Tori Trades shall be governed by the laws of the State of Nevada without regard to its conflict of law provisions and shall be exclusively resolved by a state or federal court located in Washoe County, Nevada. You agree to submit to the personal jurisdiction of the courts located within Washoe County, Nevada, for the purpose of litigating all such claims. Notwithstanding the above, you agree that Tori Trades shall still be allowed to apply for injunctive remedies (or an equivalent type of urgent legal relief) or to enforce its rights or remedies in any jurisdiction.

Tori Trades reserves the right to limit the availability of the Site, and any other products or services of Tori Trades, to any person, geographic area, or jurisdiction, in any manner and at any time, in its sole discretion.

If any provision of this Policy is found by a court of competent jurisdiction or arbitrator to be illegal, void, or unenforceable, the unenforceable provision will be modified so as to render it enforceable and effective to the maximum extent possible in order to effect the intention of the provision; and if a court or arbitrator finds the modified provision invalid, illegal, void or unenforceable, the validity, legality, and enforceability of the remaining provisions of this Policy will not be affected in any way.