Privacy Policy

IMPORTANT INFORMATION AND WHO WE ARE

CONTACT DETAILS

LT StockPicks, LLC

Attn: Data Privacy Champion

Email address: privacy@ltstockpicks.com

Our Data Privacy Champion and Data Protection Officer have been appointed to ensure that personal data is processed according to law and this policy. In many jurisdictions, you have the right to make a complaint at any time to a supervisory authority for data protection issues. We would, however, appreciate the chance to deal with your concerns, so please contact us first. LTSP acts both as a controller and processor of personal data.

CHANGES. This privacy policy may be updated by us from time to time. We will provide the updated policy on our website and a summary of material changes. Please keep us informed if your personal data changes during your relationship with us. We realize that it is important that the personal data we hold about you is accurate and current.

THIRD-PARTY LINKS. Some of our websites and services may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for how they process personal data. We encourage you to read the privacy notice of every website you visit.

THE DATA WE COLLECT

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed, such as de-identified or anonymous data. We follow the law in each applicable jurisdiction in determining what constitutes personal data.

We may collect, use, store, and transfer various kinds of data which we have grouped together as follows:

Identification Data such as a name, alias, postal address, unique personal identifier, online identifier, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.

Financial Data such as bank account, credit card and debit card numbers, and other financial information.

Commercial Transaction Information such as records of private property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Vehicle Data such as vehicle registration and licensure, vehicle identification number, vehicle pictures, damage info and repair and maintenance records.

Biometric Data such as pictures of people, and physical characteristics.

Technical Data such as internet protocol address, login data, browser type and version, time zone setting, data on devices used to access a website, service, or application, browsing history, search history, and information regarding interaction with an internet website, application, or advertisement.

Usage Data such as how you use our website or service.

Geolocation Data such as latitude and longitude for your location.

Sensing Information such as audio, electronic, visual, thermal, olfactory, or similar info.

Employment Information such as information about employment or a profession.

Education Data such as information about education.

Inference Data such as information drawn from other information reflecting preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Medical Data such as information on medical conditions and treatment.

Marketing and Communications Data such as your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use, and share Aggregated Data such as statistical or demographic data for any purpose.Aggregated Data may be derived from your personal data but is not considered personal data in law as it does not directly or indirectly identify you. For example, we may aggregate Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy policy.

We collect Special Categories of Personal Data about you, such as race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, criminal convictions and offenses only where required to provide services to you or our customers.

IF YOU FAIL TO PROVIDE PERSONAL DATA. Where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us, but we will notify you if this is the case at the time.

HOW IS DATA COLLECTED?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us data by filling in forms or by corresponding with us by post, phone, email, or otherwise. This includes data you provide when you:

apply for, inquire about, or purchase our products or services;

create an account on our website;

subscribe to our service or publications;

request marketing to be sent to you;

enter a competition, promotion, or survey; or

give us feedback.

Automated technologies or interactions. As you interact with our websites, we may automatically collect Technical, and Usage Data among others about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs, and other similar technologies. We may also receive Technical and Usage Data among others about you if you visit other websites employing our cookies.

Customers. Customers who use our tools and services may provide us personal data for use in those services.

Third parties or publicly available sources. We may receive personal data about you from third parties and public sources.

HOW WE USE YOUR PERSONAL DATA

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data other than in relation to sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

PURPOSES FOR WHICH WE WILL USE YOUR PERSONAL DATA. We use personal data when necessary to perform contracts, provide you services and to comply with our legal obligations. You WILL NOT be marketed to, and we WILL NOT sell your contact information to any third party. In general, we collect information for purposes and on the basis shown below:

Legitimate business interest means the interest of our business in conducting and managing our business to enable us to give you and the market place the best service and products and the best and most secure experience. We make sure to consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you or your employer are a party or to take steps at your request before entering into such a contract.

Comply with a legal obligation means processing your data where it is necessary for compliance with a legal or regulatory obligation to which we are subject.

OPTING OUT. You can ask us or third parties to stop sending you marketing messages at any time. Where you opt out of receiving these marketing messages, this will not affect our processing of your personal data for other non-marketing purposes such as providing a product or service to you, warranty registration, the product or service experience, or other transactions.

COOKIES. You can make choices about what cookies collect information on our websites. You may be able to set your browser to refuse all or some browser cookies. If you disable or refuse certain cookies, some parts of the website may become inaccessible or not function properly.

CHANGE OF PURPOSE. We will only use your personal data for the purposes for which we collected it, unless we consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

DISCLOSURES OF YOUR PERSONAL DATA

Your personal date WILL NOT be shared with any firm outside of LTSP.

DATA SECURITY

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed. In addition, we limit access to your personal data to those employees, agents, contractors, and other third parties who have a business need-to-know. They will only process your personal data on our instructions, and they are subject to a duty of confidentiality. We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

YOUR LEGAL RIGHTS

DATA RETENTION: How Long Will You Use My Personal Data?

We will only retain your personal data for as long as necessary to fulfill the purposes we collected it for, including for the purposes of satisfying any legal, accounting, or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Details of retention periods for various aspects of your personal data are available in our retention policy which you can request from us by contacting us. More specifically, and without limiting the generality of the foregoing, by law we have to keep basic information about our customers for at least 5 years after they cease being customers for tax, financial auditing, and record keeping purposes.

We may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

RIGHTS REQUESTS

If you wish to exercise any of the rights set out above, please contact us via the webform, on our websites, or through the contact information set out above.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. If your request provides an email address, or our records contain your email address, we may ask you to verify your identity through such address. Where additional information is required, we try to ask only information that can be corroborated through our records. We may also ask you for further information in relation to your request to speed up our response.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive, or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within the time allowed under applicable law (forty-five days for California, residents thirty days for residents in the EU and fifteen days for requests under LGPD for confirmation of the existence of or access to personal data). Occasionally it may take us longer. If so, we will notify you and keep you updated. If we deny your request, we will explain the basis for such denial. We will keep a record of rights requests and responses for at least twenty-four months in a log that will not be used for any purpose other than for record-keeping and analytics.

DOCUMENT CHANGE HISTORY

The previous policy and notice version are available here.

v.1. April 2022. This is a recent version of the Privacy Policy containing expanded information in all sections, updated applicability, content information, and links to the webform.