Privacy Policy

We appreciate that you may be concerned about the privacy of personal information that you provide to us through the Websites located at www.michaelcovel.com, www.turtletrader.com and www.trendfollowing.com (the “Websites”), and we respect your right to protect your personal information. Accordingly, we have developed this Privacy Policy to inform you of our policy and practice regarding information we collect about you on the Website. If you have additional questions about this Privacy Policy, please contact us.

What Information Do We Collect about You?

We collect two types of information: personally identifiable information (PII) and non-personally identifiable information (Non-PII), which is also referred to as aggregate and anonymous data.

PII. We collect the following types of PII about you from the following sources: Information we receive from you via orders, such as your name, company, cc, e-mail and mail addresses, and your telephone and fax numbers.

Non-PII – Web Site Usage Information: Cookies, IP Addresses and Logs. We employ “cookies” to collect information about you and your usage of the Website. A cookie is a small text file that is placed on your computer and collects information about how you use our site. If you are a customer who has logged into the site, we also gather information about your individual use of our services. We also log IP addresses and domain names, but we cannot use this technical Non-PII to identify you personally.

How do We Use Your Information?

We use PII described above to verify your identity and to process orders. Non-PII is aggregated for system administration and to monitor the Website’s usage. It is utilized to measure the number of visits to our site, average time spent, number of pages viewed and to monitor various other site statistics. This monitoring helps us evaluate how visitors use and navigate our site so we can improve the content.

How do We Share Your Information?

We do not share your PII with non-affiliated third parties for use in marketing their services or otherwise without your permission. We may disclose PII that we collect as noted above in connection with the sale, assignment, or other transfer of the business or a portion of the business of our site, including a corporate merger, consolidation, restructuring, sale of assets or other corporate change of our direct or indirect parent companies that affects us; or to respond to law enforcement requests; or where required by applicable laws, court orders, or government regulations; or to protect against misuse or unauthorized use of our site; or to protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions). We may share all the PII that we collect as noted above with the following non-affiliated entities: Governmental agencies, the Financial Industry Regulatory Authority, the National Futures Association, any securities and futures exchange, other regulatory bodies or other self-regulatory organizations and law enforcement officials such as for tax purposes or for reporting suspicious transactions; Non-financial service providers such as credit-card and billing processing, shipping, e-mail distribution, list processing and analytics or promotions management service companies. We provide these companies only with the information they need to perform their services. These service providers are restricted from using this data in any way other than to provide services for us, and they may not share or resell this data. We may disclose all of the information we collect, as described above to companies that perform marketing services on our behalf or to other financial institutions with whom we have joint marketing agreements.

Non-PII. We reserve the right to use, transfer, sell, and share aggregated, anonymous data about our users as a group for any business purpose, such as analyzing usage trends and seeking compatible advertisers and partners.

How do I Opt-out of the Disclosure and Use of my PII?

If you want to opt-out of sharing your information with non-affiliated third-parties, you may send an email with the words ‘opt out of disclosure’ in your subject line. If you select to opt-out, we will continue to share PII among our affiliates and our affiliates may continue to use PII to perform services on our behalf, to respond to communications from you, as you authorize or request, or to offer you products or services. We may also continue to share PII about you with non-affiliated third-parties as permitted or required by law. Even if you opt-out, we can continue to use and share Non-PII with both affiliated and non-affiliated third-parties.

How is My Information Protected?

We restrict access to PII about you to those employees and service providers who need to know that information. We take reasonable steps to protect the confidentiality of your PII, including physical, electronic, and procedural safeguards. We continually review our security procedures and mechanisms to ensure that reasonable protections are in place.

Links to Other Sites

The website may contain links to third-party sites that are not under our control, including those of our strategic partners and other sites with information that we feel may be useful to you. We are not responsible for the privacy practices, security or content of other sites.

How are Changes to This Privacy Policy Made?

From time to time, we may amend this Privacy Policy by posting it to the Website and changing the date on this page noting when it was last updated. Your continued use of the Website following the posting of any changes shall constitute your acceptance of the revised Privacy Policy.

Effective Date: February 1, 2010

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