CTC Trading Group, LLC and its affiliates (collectively, “CTC,” “us,” “we,” or “our”) value your privacy. This Privacy Notice explains how we collect, use, and disclose your personal information when you visit our website at https://www.chicagotrading.com or any websites, applications, or platforms that link or otherwise refer to this Privacy Notice (collectively, the “Site”) and when you use our products or services or otherwise engage with us (collectively, the “Services”). 

‍Please read this Privacy Notice carefully as it will help you make informed decisions about sharing your personal information with us. By visiting our Site or using our Services, you are accepting the practices described in this Privacy Notice.

1. What Personal Information Do We Collect?

(a) Information and identifiers about you. We may collect your name, your home address, your e-mail address, the company and/or website with which you are affiliated, company size, your role/title, social networking information, your telephone or wireless number, demographic information, and other information that may identify you as an individual or allow online or offline contact with you as an individual.

(b) Our interactions with you. We may keep a record of any interactions and correspondence between us, such as any interactions with our customer support services, any interactions you have with our other representatives, and any interactions with us on social media or posts that refer to us on social media. 

(c) Your use of our Site, including your Internet and network activity. When you access the Site, we may collect pages viewed on the Site, the time you spent on the Site, the date you visited the Site, your Internet browser type, the website from which you linked to our Site (e.g., another website or a search engine), the website you visit after our Site, and other web usage activity and data logged by our servers. We may also collect data about your Internet Protocol (“IP”) address. Such information may be used to gather demographic information, such as country of origin and Internet Service Provider.

(d) Cookies and other information from tracking technologies. Cookies are simple text files stored by your web browser that provide a method of distinguishing among visitors to the Site. CTC uses cookies to identify your browser as you visit pages on the Site and for Google Analytics tracking. Many web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. Refusing a cookie may, in some cases, preclude you from using the Site or negatively impact the display or function of the Site (or parts of it). Cookies also allow CTC to provide more relevant, targeted content as you travel through our Site. When using our Site, you will be asked to consent to our use of cookies as described in this Privacy Notice. You can withdraw your consent at any time by selecting the “Cookie Settings” link found at the lower left of every page and adjusting your settings, or you can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies (which is usually found in the Edit menu). If you refuse cookies, you may lose some of the functionality of the Site. The Site’s advertisers and other partners may also use cookies in connection with the services and websites to which our Site links. 

(e) Job applicant and employee information. We may collect your full name; contact information; citizenship / residency information; gender; ethnicity; nationality; disability information; military and veteran status (each only to the extent voluntarily provided by you with your express consent); professional or employment-related information; resume and cover letter information; references and information obtained from them; related background check information (to the extent permitted, and in accordance with applicable law); education information, including educational institutions and certificates and degrees obtained; and other information, including any other information reasonably necessary for us to carry out our legal or regulatory obligations related to your job application or employment.

2. How Do We Collect Personal Information?

We collect personal information from you when you submit information to us on the Site or through your use of the Services. For example, we collect personal information when you contact us through the Site or offline, when you purchase our products or services through the Site, when you subscribe to our newsletter. We also automatically collect certain information about you when you use the Site. 

3. How Do We Use Your Personal Information?

We may use the personal information we collect from you in the following ways:

(a)  To provide our products and services to you. To enable you to explore and purchase products; to supply, distribute, or use services (e.g., on our Site); to collect payment; to set up or verify an account for you; to respond to your warranty requests; to provide customer service; and to enable us to identify you as a user of our products and services.

(b)  To communicate effectively with you and conduct our business. To provide you with administrative emails, to engage and manage your employment, to correspond with you when you register to receive information, to communicate with you, and to inform you of changes. We will also communicate with you to provide customer support and in relation to inquiries. 

(c)  For research and development purposes. When you participate in a survey or we gather demographic information about our user base, we analyze trends about our users based on information they provide and their interactions with us. We also use certain personal information to improve our Site, products, and services.

(d)  To provide you with marketing material. To promote our services; notify you about new products and services; and to send you surveys, promotional materials, newsletters, product upgrades, and special offers about our products and services by mail, email, and through social media. We may also use your personal information to analyze our customers’ preferences and market trends and to derive insights that we may use to tailor the types of products and offers that we present to you. You may receive such contents only if you expressly consent to it by registering to receive such documents or if you are an existing customer. Depending on your jurisdiction, you may withdraw your consent at any time by opting out within the email or otherwise, or you may email CTC to opt out of receiving such content. 

(e)  To monitor certain activities. We monitor the use of some products and our Site, including users’ movements around our Site, the date and time of your visit, details of the information collected through cookies, and other tracking methodologies. We sometimes monitor activities as part of our compliance procedures and to combat fraud.

(f)  To administer our Site. Including to resolve problems and disputes with our Site, ensure that the content is relevant and presented to you in the most effective manner for you, ensure compliance with our Site’s terms and conditions and this Privacy Notice, protect the security and integrity of our Site, and notify you about updates to this Privacy Notice and our Site’s Terms of Use.

(g)  To comply with our legal obligations and enforce our rights. To comply with our regulatory requirements, conduct audits, communicate with regulators, protect CTC’s or a third party’s rights, and enforce our contracts, which may include disclosing your personal information to third parties, a court service, attorneys, regulators, or law enforcement agencies in connection with inquiries, proceedings, or investigations by such parties anywhere in the world or where compelled to do so. 

(h)  In connection with a sale, merger or reorganization of our business. If we undergo a sale, merger, or reorganization, we may need to transfer some or all of your personal information to a third party or its advisors as part of any due diligence process for the purpose of analyzing the proposed sale, merger, or reorganization or after the sale, merger, or reorganization for the same purposes as set out in this Privacy Notice. 

(i) In connection with a job application or employment. If you apply for a job with CTC or are employed by CTC, we use the information you provide to facilitate the collection, administration, and processing of your job application or your employment; to determine your suitability for the role for which you have applied or for similar roles within CTC ; to verify your eligibility to work for CTC; to conduct background checks (in accordance with applicable law) as part of your application; to process payroll; to enroll and provide benefits; to otherwise facilitate your employment at CTC; and to comply with applicable laws, company policies, and employment-related requirements. 

(j) With your consent. We may also use your personal information for any additional purpose that you consent to or that CTC notifies you of at the time of collection.

4. Legal Basis for Use of Personal Information

In some jurisdictions, we are required to identify the legal basis for processing your personal information. The purposes outlined in Sections 3(a), (b), and (g) are all essential to provide our products and services. The purposes outlined in Sections 3(c), (d), (e), and (f) are non-essential, but allow us to provide you with better products and services. The purposes outlined in Section 3 (i) are essential to collect and process job applications and to employ individuals. In the table below, we have set out the relevant grounds that apply to each purpose mentioned above in Section 3.

(a) Consent: where you have consented to our use of your personal information;

(b) Contract performance: where we are required to collect and handle your personal information in order to provide you with the services that we have contractually agreed to provide to you;

(c) Legal obligation: where we need to use your personal information to comply with our legal obligations; and

(d) Legitimate interests: where we have a legitimate interest in using your personal information. We will only rely on this legal ground if we consider that our interest in using your personal information for the relevant purpose is not outweighed by any interests that you may have, or any prejudice that you may suffer, from the relevant use of your personal information.

5. To Whom Do We Disclose Your Personal Information 

 In addition to any recipients specified in Sections 3 or 4 above, we may disclose, and have disclosed in the past twelve (12) months, personal information as described in the below table.

We do not “sell” or “share”, and have not “sold” or “shared” in the past 12 months, your personal information as defined by the California Consumer Privacy Act (“CCPA”). 

We do not sell your personal information to third parties. We may nonetheless share your personal information with third parties for a variety of reasons. 

Google Analytics tags are used to improve the design and user experience of our Site by providing statistics on site usage and pages visited. To learn more about how you can control your privacy with Google tools, see https://privacy.google.com/#(Opens in a new window) Click to opt out of Google Web Analytics altogether, see https://tools.google.com/dlpage/gaoptout Doubleclick Ad Exchange https://support.google.com/dfp_premium/answer/2839090?hl=en(Opens in a new window).

6. What Are Your Choices Around Tracking Technologies?

In accordance with your choices, we may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information in order to help us provide better customer service, enhance the user experience, and deliver personalized content. For example, we may use the following cookies: Google Analytics. 

We only set non-essential cookies (including analytics and advertising cookies) when you provide consent through our cookie banner. If you do not provide consent, these technologies do not load, and where applicable Google applies Restricted Data Processing. You can manage or withdraw your consent at any time by clicking “Cookie Settings” in the footer of our Site. This will reopen our cookie preferences panel, allowing you to opt out of analytics cookies (including Google Analytics and Microsoft Clarity) and marketing cookies (including Google Ads and the LinkedIn Insight Tag).

You may also disable cookies through your browser settings. Doing so may affect website functionality. Additional industry opt-out options are available at:

• Network Advertising Initiative: http://optout.networkadvertising.org
• Browser cookie management: https://www.google.com/intl/en/policies/technologies/managing

You can opt out of Google Analytics by:

• Changing your settings at Google’s Ad Settings at: http://www.google.com/settings/ads
• Installing an opt-out browser add-on available at: https://tools.google.com/dlpage/gaoptout/
• Adjusting the settings on your web browser: See http://www.google.com/intl/en/policies/technologies/managing

You may opt out of online behavioral ads at https://youradchoices.com/(Opens in a new window)

You also may limit certain tracking by disabling cookies in your web browser.

7. How Do We Protect Your Personal Information?

We take reasonable and appropriate precautions to protect personal information. While we endeavor to protect the security and integrity of personal information collected via the Site, due to the inherent nature of the Internet as an open global communications vehicle, we cannot guarantee that any information, during transmission through the Internet or while stored on our system or otherwise in our care, will be absolutely safe from intrusion by others, such as hackers.

8. Transfer of Personal Information

If we transfer your personal information to a country outside the European Economic Area (“EEA”) or United Kingdom (“UK”), we will provide appropriate safeguards by applying one of the following transfer solutions:

• The receiving party of the personal information is located in a country recognized by the European Commission as offering an adequate level of data protection as set out by the European Commission pursuant to the General Data Protection Regulation or by the Information Commissioner’s Office pursuant to the UK General Data Protection Regulation (including certification to the Data Privacy Framework for entities located in the US); or
• The receiving party of the personal information has agreed to process this personal information in accordance with the “Standard Contractual Clauses” for data controllers or data processors approved by the European Commission or the Information Commissioner’s Office, as applicable.

9. Data Retention and Destruction

We store your personal information for as long as it is necessary to provide our Services to you and so long as we are legally required to do so. This will depend on the purpose for processing unless we no longer need the data to provide services, or until any legal requirements to keep it no longer exist. When we no longer need personal information, we securely delete and destroy it.

10. Rights You May Have

You may have certain rights under certain conditions in relation to personal information we collect about you under applicable law. These rights do not necessarily apply to all users of our services or visitors to our Site. 

Depending on the applicable laws and under certain conditions, you may have:

• The right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing personal information, the categories of third parties to whom we disclose personal information, and the specific pieces of personal information we have collected about you.
• The right to delete personal information that we have collected from you, subject to certain exceptions.
• The right to correct inaccurate personal information that we maintain about you.
• The right to restrict processing of your personal information under the following circumstances:
  • if you object to a processing based on our legitimate interest, we will restrict all processing of such data pending the verification of the legitimate interest;
  • if you have claimed that your personal data is incorrect, we must restrict all processing of such data pending the verification of the accuracy of the personal data;
  • if the processing is unlawful, you can oppose the erasure of personal data and instead request the restriction of the use of your personal data instead; and
  • if we no longer need the personal data but it is required by you to defend legal claims.
• The right to ask us to electronically transmit the personal information you have provided to us and that we still hold about you to a third party.
• The right to withdraw consent, where processing is based on consent.
• The right to make a complaint to your local government or supervisory authority if you feel your rights have been violated; 
• The right not to receive discriminatory treatment by us for the exercise of privacy rights conferred by the CCPA.
• The right to appeal an action taken or not taken in response to your request.  

These rights are subject to certain exemptions, including without limitation to safeguard the public interest (e.g., the prevention or detection of crime) and our interests (e.g., the maintenance of legal privilege). 

To the extent applicable, you may submit requests to exercise your rights above by emailing us at: privacy@www.chicagotrading.com.

You may also designate an authorized agent to submit requests to exercise your rights on your behalf. To do so, we may require you to verify your identity (as described below) and directly confirm that you have provided the authorized agent to submit the request.

We will verify and respond to privacy requests within the timeframes required by law.

We may be required by applicable law to verify your identity for certain requests, and we may deny your request if we are unable to verify your identity. To verify your identity, we may require you to provide certain information which we will match against information we maintain about you in our systems. To the extent possible, we will generally attempt to avoid requesting additional new information we do not already have on record, but if it is necessary to request new information, we will use that new information only for verification and will delete it as soon as practical after processing the request (except as required by law). 

If the request is submitted by your designated authorized agent, we may require your authorized agent to provide proof that you have signed permission to submit the request.

11. Personal Information of Children Under 16 Years Old

CTC does not knowingly collect the personal information of children under 16 without a parent’s or guardian’s prior consent.

12. Third Party Links and Comment Sections/Forums

Occasionally, at our discretion, we may include links to other websites, including websites operated by unaffiliated third parties. These third party sites may collect personal information about you and have separate and independent privacy policies. This Privacy Notice does not address the information practices of these websites, and therefore we have no responsibility or liability for the content and activities of these linked websites. 

13. Changes to Our Privacy Notice

If we decide to change our Privacy Notice, we will post those changes on this page and such changes shall be effective immediately upon posting to this page. Under certain circumstances (for example, in connection with certain material changes), we may also elect to notify you of changes or updates to our Privacy Notice, or to request your consent for such changes, by additional means, such as posting a notice on the front page of our Site or sending you an e-mail. 

14. Contacting Us – Complaints

If you have any questions, concerns or comments about this Privacy Notice or our practices with regard to your information, you can reach us electronically at privacy@www.chicagotrading.com.