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This privacy policy applies to personal information and data collected at the www.vectorvest.com website, and to personal information and data collected by VectorVest, Inc. (“VectorVest”) for its courses, training, software, research, subscription services, free trials, marketing, and all other products and services it offers on its own or may offer on behalf of third parties including at additional websites (collectively the “Services”). VectorVest is committed to protecting the privacy of users of the Services. VectorVest does however gather certain types of information about the users of the Services, and wants users to fully understand the terms and conditions surrounding the use of the information we collect. The following discloses our information gathering and dissemination practices for the Services. VectorVest is subject to the regulatory and enforcement authority of the United States Federal Trade Commission (FTC). VectorVest also adheres to the Privacy Shield Principles (the “Principles”) which are incorporated by reference as if fully set forth herein. Further information about the US-EU Privacy Shield is available at the Privacy Shield Website.

1. Information VectorVest collects.

Users can visit the public or “free” sections of our websites without identifying themselves or volunteering personal information. But to otherwise utilize the Services and associated features, a user must first register with VectorVest. When a user registers, we may request certain personal information, including, but not limited to, contact information, such as the users name, mailing address, telephone number, e-mail address, credit/debit card information, transactional payment information, and demographic information such as age, and gender.

2. Purposes of Data Collection

VectorVest gathers, collects, stores, organizes, and retrieves information and data about users of the Services both collectively and individually. For example, we gather what areas of our websites users visit most frequently, what Services users access most often, and trends or patterns in responses to educational course questions. VectorVest automatically logs IP addresses, session sources, and other data which tracks users’ access to the Services. We analyze these logs for sales and marketing purposes, as well as for system performance monitoring. These logs are analyzed for the aggregate trends and patterns they reveal about users of the Services, not for the behaviors of individual users. This information provides us with aggregate data that VectorVest may use to improve the Services. VectorVest also gathers personal information about users of the Services individually, for example for provision of customer service and support, billing, security, compliance with the VectorVest Subscriber Agreement, network management, user surveys, sales management, sales support, newsletters, marketing, user group memberships, event registrations, sponsorships, offers of related products and services, and other exchanges of information.

3. What VectorVest does with the information it collects.

In addition to the foregoing, VectorVest may use aggregated personal information to determine the demographic composition of our user base and to distribute statistics and general marketplace information about VectorVest. This aggregate information does not identify specific users.

Certain non-personal information regarding users is recorded by the standard operation of the Internet servers hosting the Services. This information is primarily used to provide users of the Services with an enhanced online experience. VectorVest may disclose aggregated user statistics in order to describe the Services to prospective partners, advertisers, purchasers, and other third parties, and for other lawful purposes.

Some features of the Services may be offered in conjunction with an unaffiliated third party, such as another entity or brokerage offering the Services and contracting with VectorVest as a vendor to provide the Services to users. In order to provide the Services, it may be necessary for either users or VectorVest to share personal information of users with unaffiliated third parties. If a user does not want his or her information to be shared, the user can choose not to allow the transfer by not using the Services, or by following the opt-out procedures identified in section 5 below.

Also, please be aware that advertisers or websites that are linked to the Services may collect personally identifiable information about users. The information practices of those websites linked to the Services are not covered by this privacy policy and VectorVest is not responsible for the privacy practices or the content of such websites.

VectorVest utilizes other companies to provide limited services on its behalf, including but not limited to customer support, web analytics, coordination of mailings and event management. These companies are permitted to access only the information they require to perform those services. VectorVest requires these companies to maintain the confidentiality of any personal information and data and prohibits them from using the information for any other purpose than the purpose for which it was collected.

The personal information and data users of the Services supply to VectorVest may also be given, sold, rented, loaned, disseminated, or disclosed to third parties outside of VectorVest for sales and marketing purposes and solicitations. If a user does not want his or her information to be shared, the user can choose not to allow the transfer by not using the Services, or by following the opt-out procedures identified in section 5 below. The personal information and data users of the Services supply to VectorVest may also be given, transferred, disseminated, or disclosed to third parties under special circumstances, such as when we believe in good faith that disclosure is reasonably necessary to (i) comply with legal process, (ii) enforce any terms of use of the Services, (iii) respond to claims that any content provided by using the Services violates the rights of third parties, (iv) protect the rights, property, or personal safety of VectorVest, its users, or the public, (v) enter into or comply with a contract, or (vi) complete an audit of any kind. Please know that VectorVest may be required to release an individual’s personal information in response to a lawful request by public authorities especially to accommodate national security or law enforcement requirements. Before any user’s personal information or data will be transferred by us to third parties for commercial purposes, including for sales and marketing, we will first obtain from the third party a contract assuring that it too abides by the Privacy Shield and Safe Harbor framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of data from the European Union and Switzerland, or in the alternative we will obtain a written agreement from the third party that it will adhere to such safe harbor framework and principles.

In cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-US Privacy Shield, VectorVest is potentially liable. To learn more about the Privacy Shield program, and to view VectorVest’s certification, please visit https://www.privacyshield.gov/

4. What is a cookie?

A cookie is a small data file that certain websites write to your hard drive when you visit them. A cookie file can contain information that allows a website to track the pages you’ve visited. But the only personal information a cookie can contain is information you supply yourself. A cookie can’t read data off your hard disk or read cookie files created by other sites. VectorVest uses cookies to tell when a user is a repeat visitor and to let us know how the user found the site. They also allow us to automatically link users to their personalized accounts. When you create an account, VectorVest may use a cookie to store a unique, random code. VectorVest only uses this code to identify you anonymously in our database and to track the pages you visit on our site. This helps us better understand and improve areas of the site that our users find valuable. VectorVest also uses this code to enable you to enter various Services areas without having to log in each time. Some of the services will not work if you have cookies disabled.

5. User Options — Opt-Out

Users of the Services should contact us at the address below with any questions about the information that we collect from users. Users may opt out of receiving any future direct marketing or promotional electronic mailings from VectorVest by following the unsubscribe procedures indicated in the mailing. Additionally, if a user does not want his or her information to be shared, or does not wish to receive telephone solicitations, users may opt out of the sharing or solicitations by calling us at (888) 658-7638, writing to us at the address below, or emailing us at support@vectorvest.com, indicating that he or she wishes to opt out.

6. User Access to Information

VectorVest acknowledges the individual’s right to access their personal data. VectorVest offers users the ability to edit, correct, or change the information and data collected during registration. Users may change this information at any time and as often as necessary by choosing the “edit account” option or other similar functionality offered in the Services. To access or change your personal information, log in to your account through the Services. For editing data not available through such an account, please call us at (888) 658-7638, write to us at the address below, or email us at support@vectorvest.com.

7. Security

All user personal information is stored on servers at a location designed specifically to ensure that no unauthorized individuals have access to the server or its data. We also have appropriate managerial procedures in place to safeguard the information we collect.

8. European Union Data Protection for Residents of the EU

VectorVest complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. VectorVest has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability. If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification page, please visit https://www.privacyshield.gov/

9. Complaints and Dispute Resolution for Residents of the EU

In compliance with the EU-US Privacy Shield Principles, VectorVest commits to resolve complaints about your privacy and our collection or use of your personal information. European Union individuals with inquiries or complaints regarding this privacy policy should first contact VectorVest via:

call us at (888) 658-7638, write to us at the address below, or email us at support@vectorvest.com.

VectorVest has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles to BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and go to http://www.bbb.org/EU-privacy-shield/file-a-complaint/ to file a complaint.

Finally and under limited circumstances, complaints not resolved through these channels may seek redress before the Privacy Shield Panel, a binding arbitration independent recourse mechanism.

10. Complaints and Dispute Resolution for Residents outside of the EU and Switzerland

If you reside outside of the EU or Switzerland and have any complaints about this privacy policy, or related to your personal information and data, please contact us at the address and contact information in Section 13 below.

11. User Consent

By using the Services, users signify their assent to this privacy policy and to the collection, use and dissemination of their personal information and data, including to third parties, as described herein, and for the purposes described herein. If a user does not agree to this policy, or to the collection, use and dissemination of their personal information and data, including to third parties, as described herein, and for the purposes described herein, he or she should not use the Services, or follow the opt-out procedures identified in section 5 above.

12. Changes to Privacy Policy

If VectorVest changes this privacy policy, we will post those changes at www.vectorvest.com/privacy so that users will always know what information we gather, how we might use that information, and whether we will disclose it to anyone. Continued use of the Services by a user following the posting of changes to these terms will likewise mean the user accepts those changes.

13. Contact Us

If you have any questions or complaints regarding this policy, please contact:

Mrs. Linda Royer
Secretary/Treasurer
VectorVest, Inc.
2650 W. Market Street Ste 1A
Akron OH 44333
e. lindar@vectorvest.com
p. (330) 867-2814, ext. 502
f. (216) 803-0880

Revision Date: 11/08/2016

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