Privacy Policy - Strad Pro

effective February 14, 2020

Applicability of This Policy to Our Strad Platform

This Privacy Policy describes the practices of Dow Software, LLC (“we”, “us” or “our”) with respect to personal information we collect from and about users (“you”, “your” or “users”) or our Strad platform (the “Platform” or “Strad”).

By using Strad, you acknowledge that you have read and understand the terms of this Privacy Policy. This Privacy Policy may be revised periodically, and any such revisions will be reflected by the effective date above. Please revisit this page to stay aware of any changes.

Privacy is important to us. We will never rent or sell your personal information to anyone. If you have any questions or if you believe that we have not adhered to this Privacy Policy, please send us a note at [email protected].

Please refer to our Terms of Use for the definitions of the following terms used below: Registered Users, Advisors, Clients, Authorized Users, User Administrators, and Approved Viewers (collectively, “Users”).

Collection and Use of Personal Information.
We collect information about you, including information that directly or indirectly identifies you, through your use of the Platform. We do so:

Collection and Use of Personal Information.

We collect information about you, including information that directly or indirectly identifies you, through your use of the Platform. We do so:

When you (or other authorized Registered Users, if any, including your Advisors, Clients, Authorized Users and User Administrators) provide the information, through filling out forms or otherwise providing information on the Platform;
When we connect to your financial institutions in order to retrieve transaction data on your behalf; and
When you correspond with us to receive customer support.

This personal information includes:

Registration Information: We collect your name, postal address, email address, IP address, username, password and similar identifiers, in order to enable your creation and use of a personalized Strad account, and to allow us to provide you with messages, notifications and alerts relating to the Platform and with customer support.
Financial Information: In order to enable you (and other authorized Registered Users, if any) to populate your Strad account with financial information, we or our third-party affiliates collect, when you choose to provide them to us in connection with our account aggregation features, your login credentials (including usernames and passwords) for the accounts you link to our Platform, account security and/or challenge questions for those accounts and other information from the financial accounts that you link to our Platform or in connection with which you manually submit information to our Platform (including account balances, transactions and holdings).
Payment Information: In order to facilitate payment processing and recordkeeping, we collect details of transactions you carry out through or in relation to our Platform (such as payment of Platform subscription fees) and of the fulfillment of your orders.
Relationship Information: We collect identification and contact information of your advisors and deputies to whom you may provide access to your Strad account.

Sharing of Personal Information.

We do not sell personal information. We may disclose or transfer personal information that we collect or you provide as described in this privacy policy: (i) to contractors, service providers, and other third parties we use to support our business, in particular providing infrastructure and analytics services, and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them, which includes third-party aggregation partners who use your Financial Information to gather and maintain your account balances, transactions, and holdings used to provide our Platform; (ii) to fulfill any other purpose disclosed by us when you provide the information or consented to by you, including to Approved Viewers where you have consented to the designation of certain Registered Users as Approved Viewers; (iii) with our affiliates or any successor to all or part of our business; (iv) in order to comply with a subpoena, court order, or applicable law; and (v) in order to protect the rights, property, or personal safety of users, us, or the public.

Security of Personal Information.

We take reasonable measures designed to protect personal information from unauthorized access and against unlawful processing, accidental loss, destruction, and damage.

Retention and Deletion of Personal Information.

This section of the Privacy Policy does not apply to aggregated or de-identified user data that cannot reasonably be used to identify you. We may retain your personal information for the duration of your use of or access to our Platform. We may retain your personal information for longer as necessary and relevant to our legitimate operations in accordance with applicable laws.

Your Choices and Rights.

You have choices and rights with respect to how we collect and use your personal data.

Rights and Requests: You can contact us at any time using the contact information listed in the last section of this Privacy Policy to request we do any of the following: (i) erase or delete all or some of your personal information; (ii) change, update, or correct your personal information; (iii) restrict how we use all or some of your personal information; (iv) access your personal information and, where applicable and feasible, request to receive that information in a commonly used electronic format (or ask for this information to be provided in that format to a third party); or (v) disclose what personal information we collect, use, disclose or sell. We will consider and respond to any such requests promptly and otherwise in accordance with applicable laws.

Note for California Residents: California residents should note the following;

With respect to our compliance with California law, we do not sell personal information, and we disclose personal information only to the categories of third parties described above under “Sharing of Personal Information.”
California law provides consumers with certain data rights with respect to the personal information businesses collect, including: (1) the right to know (a) the specific pieces of personal information we have collected about you, (b) the categories of personal information we have collected about you, (c) the categories of sources from which your personal information is collected, (d) the categories of personal information that we have disclosed for a business purpose about you, (e) the categories of third parties to whom personal information was disclosed for a business purpose, and (f) the business or commercial purpose for collecting personal information; and (2) the right to request that we delete personal information about you that we have collected (unless an exception applies or deletion is otherwise restricted or prohibited by law, rule, or regulation).
You may submit a verifiable request to exercise your California data rights emailing us at [email protected]. We may ask you for additional information in order to verify your identify before responding to such requests, but we will use such additional information only for purposes of such verification.
Under California law, you have a right not to receive discriminatory treatment by a business for the exercise of your consumer privacy rights conferred by California law.

Note for California Residents: California residents should note the following; While our focus is generally on the United States, insofar as we may from time to time process personal information of individuals in the European Union, Iceland, Liechtenstein, Norway, or the United Kingdom, which processing may be subject to the European Union’s General Data Protection Regulation (“GDPR”), please note the following:

Dow Software, LLC is headquartered in Lakewood Ranch, Florida, in the United States. Our full contact information is provided in the last section of this Privacy Policy.
We will only process your personal information to the extent applicable law allows us to do so.
The United States has not sought nor received a finding of “adequacy” from the European Union under Article 45 of the GDPR. We rely on derogations for specific situations as set forth in Article 49 of the GDPR. In particular, we collect and transfer personal information to the U.S. only: with your consent; to perform a contract with you; or to fulfill a compelling legitimate interest in a manner that does not outweigh your rights and freedoms.
If you have any complaints regarding our privacy practices or how we handle any requests you make in accordance with the “Rights and Requests” section above (which requests you may have a legal right to make and we may have a legal obligation to honor, as dictated by applicable law), you may also lodge a complaint with your national data protection authority (contact information available here).

Children.

Our Platform is not directed towards anyone under the age of 18. If a parent or guardian becomes aware that their child under the age of 18 has created an account on Strad and/or provided us with personal information, please contact us at [email protected]. Additionally, if we become aware at any point that a child under the age of 18 is using our Platform, we will terminate their account.

Contact Us.

Any comments, concerns, questions, or specific requests relating to this Privacy Policy should be directed to Dow Software, LLC at 8205 Nature’s way, Suite 219, Lakewood Ranch, Florida 34202 or [email protected].