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Privacy Policy

1. Welcome. Welcome to the website of Neurogenetic Trading Strategies, LLC. This Privacy Policy summarizes our practices and policies regarding the collection and management of information from or about those who visit or interact with this website (referred to herein as “Users”), so that they may make an informed decision about sharing information with us. All references to "Neurogenetic”, "we" or "us" in this Privacy Policy shall refer only to Neurogenetic Trading Strategies, LLC. For purposes of this Privacy Policy, an “Affiliate” of any person or entity means any other person or entity owned or controlled by, owning or controlling, or under common ownership or control with the first person or entity, and the adjective “Affiliated” has the corresponding meaning.

2. Scope. Neurogenetic offers information about, and access to products and services in, the field of financial trading and analysis utilizing the tools of neural network software and genetic algorithm, and in doing so collects certain information from Users needed or useful to enable the delivery of such information and access. Interaction with this website by Users is subject to the terms and conditions set forth in the Terms of Use, this Privacy Policy and, to the extent applicable, the Neurogenetic Forum User Agreement.

3. Third Parties. This website includes information about, links to websites of, and/or advertisements placed by third parties not Affiliated with Neurogenetic regarding their own or their licensors’, suppliers’ or vendors’ products or services. Those third parties may also collect information from Users upon their access to or interaction with such information, websites or advertisements. Neurogenetic is not responsible for the privacy policies or practices of such third parties, and this Privacy Policy does not purport to represent or summarize their respective privacy policies, if any. Users are responsible for reviewing and assessing the acceptability of applicable privacy policies of such third party websites.

4. Children's Privacy. Neither this website nor the information, products or services accessible in or through this website are developed for, directed at, or authorized for use by children.

5. Collection and Use of Information Generally. Neurogenetic may monitor, retrieve, store, modify, transmit and otherwise use any data and information submitted, stored or received by Users, including but not limited to Personally Identifiable Information (defined below), as reasonably necessary or appropriate in the course of operating this website and making available to Users its features, functionality or other content. For this purpose, “Personally Identifiable Information” includes information that identifies or could be used to identify a particular individual User, together with any other data recognizably associated with such information, and may include information about Users’ personnel and authorized users furnished in the course of interacting with this website.

6. Collection of Non-Personally Identifiable Information. Neurogenetic and/or its advertisers and third-party providers may collect non-Personally Identifiable Information such as internet protocol (“IP”) addresses, browser types, operating systems, domain names, language preference, access dates and times, referring website addresses, online transactions and browsing and search activity, including through the use of log files, web beacons and cookies. "Log files" store tracked actions occurring on websites and collect data including the User’s IP address, browser type, referring uniform resource locator (“url”), request url, user agent, browser accept language, platform type, and date/time stamp (for clicks and sales/leads only), advertisements viewed, and similar technical data associated with the User’s interaction with a website. "Web beacons" are pixels used to track the User’s navigation of a website or collection of sites, the completion of transactions, submittal of applications and browsing behavior. "Cookies" are anonymous, unique identification scripts or codes that are stored by the host website on the User’s internet browse to enable the User to maintain access to the website for the duration of the session, and/or to gain access to different levels of content, features or functionality. "Session Cookies" are used only during the User’s visit to the website and normally deleted once the User closes his or her browser, although it might be possible for the user or others having access to the computer to use certain data retrieval technologies to recover such “deleted” information. "Persistent Cookies," on the other hand, remain on the User’s browser for a pre-determined period of time, enabling the host website to remember the User and to provide more relevant content on subsequent visits. In neither case do they contain code that could damage the User’s computer or retrieve the User’s e-mail address or other Personally Identifiable Information. While it is technically possible for Users to disable the “cookies” feature of their web browsers, Users should note that disabling “cookies” may prevent access to certain features and services in Neurogenetic’s website, or disable the User’s access altogether.

7. Use of Non-Personally Identifiable Information. Information so collected may be aggregated and stored in our records, disclosed to our employees, consultants or technical service providers for purposes of technical support and connectivity requirements, or shared with advertisers and other third party providers in order to enhance or maintain the quality of our services, to more effectively match advertisements and website content to Users’ interests, or to administer the terms of our relationships with those advertisers and other third party providers. For example, Cookies may be used to indicate to our third-party providers that a particular User was referred to the third party’s website by reason of the User’s interaction with this website. This enables Neurogenetic to be credited for having generated the lead for purposes of the third party’s marketing program. Cookies may also be used to measure the reach of an advertising campaign, or to control the delivery of advertisements to a single internet browser, or to develop a predictive statistical user profile of the User's needs and interests. Cookies may also be used to enable the User to access different levels of this website’s content, features and functionality. Such uses do not identify the User personally, and Neurogenetic and its third-party providers reserve the right to retain all ad delivery and reporting data as long as may be reasonably necessary for accounting and audit purposes.

8. Collection and Use of Featured Product Registration Information. Users who register to gain access to Neurogenetic’s “Featured Products” submission feature will be required during registration to choose a registration username, password and email address, and in addition furnish certain additional Personally Identifiable Information such as a company contact name, phone number, email address, street address, website address, or similar contact information. This information is needed and used to validate the User’s input, or to otherwise verify User credentials both prior to registration and on each attempt to gain access to the password-protected areas of this website, to communicate with the registered User regarding his or her account and product(s), to publicize where appropriate the applicable product(s) and company contact information in the “Featured Products” summaries and, except to the extent that the User has opted out of receiving such notices, to alert the User to new developments and opportunities to receive additional products, services or other benefits from Neurogenetic or third parties with whom Neurogenetic maintains a marketing relationship. While the registration username, password and email address are not collected for publication as such in the “Featured Product” summaries, the company contact information is collected and intended for publication. To the extent that the user chooses a registration username, password or email address identical to or included in any company contact information so collected, therefore, these items would be subject to publication as well. This website enables each registered User to submit and maintain directly all Personally Identifiable Information stored by the User in Neurogenetic’s database from time to time; such information is submitted by the User voluntarily and manually, and the User may edit or delete the information in his or her account at all times that the Featured Product “edit” feature remains functional. To the extent that any Personally Identifiable Information is nevertheless posted by persons other than the User to whom such information pertains, the User may request the deletion or modification of such information, whereupon Neurogenetic shall implement such request as promptly as reasonably practicable. While Neurogenetic is not responsible for the content, maintenance or accuracy of such information, Neurogenetic may from time to time modify its format or implementation in the ordinary course of administering the database and managing and updating the website and its content, features and functionality. To the extent that any Personally Identifiable Information is nevertheless posted by persons other than the User to whom such information pertains, the User may request the deletion or modification of such information, whereupon Neurogenetic shall implement such request as promptly as reasonably practicable.

9. Collection and Use of Neurogenetic Forum Registration Information. Users who register to gain access to the Neurogenetic Forum (the “Forum”) will be required during registration to choose a registration username, password and email address, but are not thereby required to submit other Personally Identifiable Information. The information so collected is needed and used to validate the User’s input, or to otherwise verify User credentials both prior to registration and on each attempt to gain access to the password-protected areas of this website, to communicate with the registered User regarding his or her account, to enable publication of the User’s Forum postings and, except to the extent that the User has opted out of receiving such notices, to alert the User to new developments and opportunities to receive additional products, services or other benefits from Neurogenetic or third parties with whom Neurogenetic maintains a marketing relationship. While the registration username, password and email address as such are not collected for publication, information posted to the Forum itself by any User is collected and intended for publication. To the extent that the user chooses a registration username, password or email address identical to or included in any Forum postings so collected, therefore, these items would be subject to publication as well. This website enables each registered User to submit and maintain directly all Personally Identifiable Information stored by the User in Neurogenetic’s database from time to time; such information is submitted by the User voluntarily and manually, and the User may edit or delete the information in his or her account at all times that the Forum User account “edit” feature remains functional. To the extent that any Personally Identifiable Information is nevertheless posted by persons other than the User to whom such information pertains, the User may request the deletion or modification of such information, whereupon Neurogenetic shall implement such request as promptly as reasonably practicable. While Neurogenetic is not responsible for the content, maintenance or accuracy of such information, Neurogenetic may from time to time modify its format or implementation in the ordinary course of administering the database and managing and updating the website and its content, features and functionality.

10. Other Uses of Personally Identifiable and/or non-Personally Identifiable Information. Neurogenetic reserves the right to develop for its internal use, and to provide its advertisers and sponsors with, de-identified aggregate information about website users and visitors, including usage patterns, user preferences and demographics, so as to facilitate the more accurate placement of advertising and other content and to develop useful new features, functionality and other content, the ownership of which de-identified aggregate information vests entirely in Neurogenetic upon its creation. In addition, Neurogenetic may share both Personally Identifiable Information and non-Personally Identifiable Information (1) to enable third party service providers to assist or facilitate in the services we provide to Users and/or our clients and customers; (2) to comply with applicable laws and regulations or to respond to a subpoena, search warrant or other lawful request for information received by us, whether or not a response is required by applicable law; (3) to enforce our terms of use and other agreements or to protect our rights; (4) to protect the safety of members of the public and users of our services; (5) for non-Personally Identifiable Information only, with advertisers and other third party providers for marketing purposes; (6) with vendors, administrative service providers, technology providers, and carefully selected business associates for data validation, enhancement, information verification and suppression services; or (7) for any other purpose for which the User provides consent.

11. Neurogenetic's Policy. Subject to the foregoing, Neurogenetic’s policy is to use commercially reasonable and appropriate measures to protect Users’ Personally Identifiable Information and to comply with requirements of applicable law in regards to the use, disclosure, modification, deletion or other disposition of, such information; provided, however, that our advertisers and other third party providers to whom the User voluntarily chooses to submit Personally Identifiable Information in registering and transacting with their websites and other platforms may combine such information with other non-Personally Identifiable Information obtained through our website. However, no transmission of information is guaranteed to be completely secure, and unauthorized entry or use, hardware or software failure, and other factors may compromise data security. By accessing this website, each User acknowledges and agrees to assume this risk when communicating with us. Except as otherwise described in this Privacy Policy, all Personally Identifiable Information is collected, modified (as needed) and stored in a password protected environment, and will not be sold, rented or leased to third parties not Affiliates of Neurogenetic. Neurogenetic undertakes no obligation of confidentiality or non-disclosure with respect to any non-Personally Identifiable Information collected from or about Users or their interactions with this website.

12. Opting Out of E-Mail Communications. If a User wishes not to receive email communications from Neurogenetic, the User may submit an email to administrator@neurogenetic.com with the word “Remove” in the subject line, whereupon Neurogenetic will remove that user from its email contact list as promptly as reasonably practicable.

13. Modifications to this Privacy Policy. Neurogenetic reserves the right to modify its privacy and security policies and practices from time to time. Such changes may be reflected in updates to this Privacy Policy at any time, and are considered binding and in force upon such publication. Users are encouraged to review this page frequently so as to remain informed about Neurogenetic’s policy as in effect from time to time. By accessing this website, each User agrees to and accepts the terms and conditions of this Privacy Policy as in force at the time of each such access.

14. Transfer on Merger, Sale or Other Event. In the event that Neurogenetic is acquired by or merged with a third party entity, or all or substantially all of its assets are sold, assigned or transferred to a third party, or upon the occurrence of a change of control of Neurogenetic or its bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application to Neurogenetic of laws or equitable principles affecting creditors' rights generally, the information collected by Neurogenetic from Users may be transferred or assigned as part of such merger, acquisition, sale, change of control or other specified event, but to the extent permitted by applicable law the obligations of this Privacy Policy shall remain binding on Neurogenetic’s successors and assigns.

15. Governing Law. The European Union ("EU") and the United States of America ("US") have by mutual agreement established a set of guiding data privacy principles known as the "Safe Harbor", which this Privacy Policy is intended to satisfy. (For more information see www.export.gov/safeharbor/.) By providing information to Neurogenetic, each User (i) acknowledges that Neurogenetic operates in the US, (ii) agrees to permit us to transmit and use such User’s information anywhere necessary, including across international boundaries, to better improve the services and transactions provided by Neurogenetic and/or its advertisers and other third-party providers, and (iii) agrees that such use by us shall be subject to the terms and conditions stated in this Privacy Policy and the Terms of Use, and applicable laws of the State of Texas and the US. It is the express wish of the parties that this Privacy Policy and all related documents have been drawn up in the English language and that the English version of this Privacy Policy shall be the sole version used in interpreting and enforcing this Privacy Policy. C'est la volonté expresse des parties que la présente convention ainsi que les documents qui s'y rattachent soient rédigés en anglais.

16. Communications. If you have any questions about this Privacy Policy, please email us at administrator@neurogenetic.com or send correspondence to us at the following address: Neurogenetic Trading Strategies, LLC, Privacy Officer, 12 Greenway Plaza, Suite 1100, Houston, Texas 77046.

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