ADVANCED

Privacy Policy

Effective Date: 06/14/2017

TRUSTe Privacy Certification

This privacy policy applies to the web sites cordium.com, and any content from or through the web sites, including any subdomains (these are referred to in this document collectively as the “Web Sites”), owned and operated by HedgeOp Compliance, LLC, a Delaware limited liability company, doing business as Cordium (“Cordium”) (referred to either as “Cordium”, “we” or “us”). This privacy policy describes how Cordium collects, uses, shares and secures the personal information you provide on the Web Sites. It also describes the choices available to you regarding our use of your personal information and how you can access and update this information.

EU-U.S Privacy Shield and Swiss-U.S. Privacy Shield

Cordium participates in and has certified its compliance with the EU-U.S. Privacy Shield Framework and the Swiss-U.S. Privacy Shield Framework. Cordium is committed to subjecting all personal data received from European Union (EU) member countries and Switzerland, respectively, in reliance on each Privacy Shield Framework, to the Framework’s applicable Principles. To learn more about the Privacy Shield Frameworks, and to view our certification, visit the U.S. Department of Commerce’s Privacy Shield List at https://www.privacyshield.gov/list.

Cordium is responsible for the processing of personal data it receives, under each Privacy Shield Framework, and subsequently transfers to a third party acting as an agent on its behalf. Cordium complies with the Privacy Shield Principles for all onward transfers of personal data from the EU and Switzerland, including the onward transfer liability provisions.

With respect to personal data received or transferred pursuant to the Privacy Shield Frameworks, Cordium is subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, Cordium may be required to disclose personal data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) http://feedback-form.truste.com/watchdog/request.

Under certain conditions, more fully described on the Privacy Shield website https://www.privacyshield.gov/article?id=How-to-Submit-a-Complaint, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted.

  1. Information Collection and Use

We may collect the following personal information from you:

  • Contact Information such as name, email address, mailing address, phone number
  • Information about your business such as company name, company size, business type
  • Financial information such as brokerage account information

We use this information to:

  • Assess the needs of your business to determine suitable products
  • Send you requested product or service information
  • Respond to customer service requests
  • Administer your account
  • Send you a newsletter
  • Respond to your questions and concerns
  • Improve our Web sites and marketing efforts
  1. Information Sharing

We will share your personal information with third parties only in the ways that are described in this privacy policy. We do not sell your personal information to third parties.

Service Providers

We may provide your personal information to companies that provide services to help us with our business activities such as inputting your contact information into our CRM or email marketing system. These companies are authorized to use your personal information only as necessary to provide these services to us.

Legal Disclaimer

We may also disclose your personal information:

  • As required by law, such as to comply with a subpoena, or similar legal process
  • When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request,
  • If Cordium is involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our Web site of any change in ownership or uses of your personal information, as well as any choices you may have regarding your personal information,
  • To any other third party with your prior consent to do so
  1. User Access and Choice

Upon request Cordium will provide you with information about whether we hold of your personal information.  To request this information please email marketing@cordium.com

If your personally information changes, or if you no longer desire our service, you may ask to have it corrected, amended, removed or deleted by emailing our Marketing Department at marketing@cordium.com or by contacting us by telephone or postal mail at the contact information listed below. We will respond to your request to access within 30 days.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

 Opt-Out Preferences

If you wish to subscribe to our newsletter(s), we will use your name and email address to send the newsletter to you. Out of respect for your privacy, you may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails, accessing the email preferences in your account settings page or you can contact us at marketing@cordium.com. 

  1. Tracking Technologies / Cookies

Cordium and our partners, affiliates or analytics or service providers (such as website developers and SEO specialists) use cookies or similar tracking technologies. These technologies are used in analyzing trends, administering the website, tracking users’ movements around the site, and gathering demographic information about our user base as a whole. You can control the use of cookies at the individual browser level but if you choose to disable cookies, it may limit your use of certain features or functions on our website or service. We may receive reports based on the use of these technologies by these companies on an individual and aggregated basis.

We partner with a third party to either display advertising on our website or to manage our advertising on other sites. Our third party partner may use technologies such as cookies to gather information about your activities on this website and other sites in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here (or if located in the European Union, click here). Please note this does not opt you out of being served ads. You will continue to receive generic ads. 

Analytics / Log Files

As is true of most web sites, we gather certain information automatically. This information includes internet protocol (IP) addresses, browser type, internet service provider (ISP), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and clickstream data to analyze trends in the aggregate and administer the site. 

  1. Security

The security of your personal information is important to us. We follow generally accepted standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security. If you have any questions about the security of your personal information, you can contact us at marketing@cordium.com. 

  1. Additional Information

Links to 3rd Party Sites

Our Sites include links to other Web sites whose privacy practices may differ from those of Cordium. If you submit personal information to any of those sites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policy of any Web site you visit. 

Testimonials

We display personal testimonials of satisfied customers on our website in addition to other endorsements. With your consent, we may post your testimonial along with your name. If you wish to update or delete your testimonial, you can contact us at marketing@cordium.com.

Social Media Widgets

Our Web site may include Social Media Features, such as the Facebook “like” button, Share This button or interactive mini-programs that run on our Sites. These features may collect your IP address, which page you are visiting on our site, and may set a cookie to enable the Feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Sites. Your interactions with these Features are governed by the privacy policy of the company providing it.

Changes To This Policy

We may update this privacy policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Site prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

  1. Contact Us

Cordium – US
3 Park Avenue, 14th Floor

New York, NY 10016

212-515-2800

marketing@cordium.com.

Cordium- UK
Norfolk House

31 St James’s Square

London

SW1Y 4JJ

United Kingdom

+44 20 7408 2448

marketing@cordium.com.