Privacy Policy

1. Introduction

ITL LLC ("we", "us", "our", or "Company") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, store, and safeguard your information when you use our website, services, and related applications (collectively, the "Services").

By using our Services, you consent to the collection and use of information in accordance with this Privacy Policy. If you do not agree with our policies and practices, do not use our Services.

2. Information We Collect

Information You Provide Directly:

• Account Information: Name, email address, username, password, and other registration information
• Payment Information: Credit card numbers, billing addresses, and payment history (processed securely through Stripe, Inc. - we do not store full credit card numbers)
• Profile Information: Preferences, settings, and account configuration
• Communications: Correspondence, feedback, support requests, and survey responses
• Trading Preferences: Asset class selections, notification preferences, and other trading-related settings

Information Collected Automatically: Usage data, device information, IP address, browser type, log data, cookies, and approximate location derived from IP address.

Information from Third Parties: Authentication data from Better Auth, transaction information from Stripe, and market data from third-party providers.

3. How We Use Your Information

We use the information we collect for the following purposes:

• Service Provision: Provide, maintain, and improve our Services, create and manage accounts, process transactions
• Communications: Send technical notices, security alerts, support messages, and service updates
• Personalization: Customize your experience and remember your preferences
• Analytics: Monitor usage patterns, trends, and performance to improve our Services
• Security: Detect, prevent, and address fraud, security threats, and unauthorized access
• Legal Compliance: Comply with legal obligations, respond to legal requests, and enforce our Terms of Service
• Marketing: Send promotional communications (with your consent and ability to opt-out)

4. Information Sharing and Disclosure

We do not sell your personal information. We may share your information in the following circumstances:

Service Providers: We share information with third-party service providers who perform services on our behalf, including:

• Stripe, Inc. - Payment processing and billing services. Stripe's privacy policy: https://stripe.com/privacy
• Better Auth - Authentication and user management services.
• Market Data Providers - Third-party providers of trading signals and market data
• Cloud Hosting Providers - Infrastructure and hosting services
• Analytics Providers - Website and application analytics services
• Email Service Providers - Email delivery and marketing services

Legal Requirements: We may disclose your information if required by law, court order, legal process, or government request, or to:

• Comply with legal obligations
• Respond to subpoenas, warrants, or other legal requests
• Enforce our Terms of Service
• Protect our rights, property, or safety
• Protect the rights, property, or safety of our users or others
• Investigate fraud or security issues

Business Transfers: In the event of a merger, acquisition, reorganization, bankruptcy, or sale of assets, your information may be transferred to the acquiring entity.

With Your Consent: We may share your information with third parties when you explicitly consent to such sharing.

5. Data Security

We implement appropriate technical and organizational security measures designed to protect your personal information against unauthorized access, alteration, disclosure, or destruction. These measures include:

• Encryption of data in transit using SSL/TLS
• Secure authentication and access controls
• Regular security assessments and vulnerability testing
• Employee training on data security
• Limiting access to personal information to authorized personnel
• Secure data storage and backup procedures

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security. You use our Services at your own risk.

In the event of a security breach that compromises your personal information, we will notify you and relevant authorities as required by applicable law, including state and federal breach notification laws.

6. Data Retention

We retain your personal information for as long as necessary to:

• Provide you with our Services
• Comply with legal obligations
• Resolve disputes and enforce our agreements
• Maintain security and prevent fraud

When we no longer need your personal information, we will delete or anonymize it in accordance with our data retention policies. Some information may be retained for longer periods as required by law or for legitimate business purposes.

If you request deletion of your account, we will delete or anonymize your personal information within 30 days, except where we are required to retain it for legal or regulatory purposes.

7. Cookies and Tracking Technologies

We use cookies, web beacons, pixels, and similar technologies to remember your preferences, authenticate you, analyze usage patterns, and provide personalized content. You can control cookies through your browser settings, though disabling certain cookies may limit your ability to use some features of our Services.

8. Your Privacy Rights

Depending on your location, you may have certain rights regarding your personal information:

Access: Request access to your personal information we hold

Correction: Request correction of inaccurate or incomplete information

Deletion: Request deletion of your personal information (subject to legal retention requirements)

Opt-Out: Opt out of marketing communications and certain data processing activities

To exercise these rights, please contact us at support@tradinglicks.net. We will respond to your request within the timeframes required by applicable law.

9. Children's Privacy

Our Services are not intended for individuals under the age of 18. We do not knowingly collect personal information from children under 18. If you are a parent or guardian and believe your child has provided us with personal information, please contact us immediately at support@tradinglicks.net. If we become aware that we have collected personal information from a child under 18, we will delete such information promptly.

We comply with the Children's Online Privacy Protection Act ("COPPA") and do not knowingly collect, use, or disclose personal information from children under 13.

10. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. The "Last Updated" date at the top of this page indicates when changes were made.

If we make material changes to this Privacy Policy, we will notify you by:

• Posting the updated policy on our website
• Sending an email to the address associated with your account
• Displaying a prominent notice on our Services

Your continued use of our Services after changes become effective constitutes acceptance of the updated Privacy Policy.

11. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our privacy practices, please contact us at:

ITL LLC
Email: support@tradinglicks.net

We will respond to your inquiry within a reasonable timeframe and in accordance with applicable law.