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SMTM (referred to herein as “we” or “us”) provides certain free and paid program's, educations, and market information services through its web site located at (the “Site”) and via email, text or other delivery methods (“Services”). In consideration us providing, or continuing to provide, you (you may be referred to herein as “you” or “user”) with access to the Site and the Services, you hereby agree that your use of this Site and any Service shall be expressly pursuant to and conditioned upon your agreement to the following Terms and Conditions (“Terms”).1. 

Acknowledgement of Disclosures and Disclaimers

  1. You hereby acknowledge and agree that:
  2. Neither SMTM nor any of its owners, directors, officers, employees, agents, independent contractors or affiliates are registered as an investment adviser. Rather SMTM relies upon the “publisher’s exclusion” from the definition of “investment adviser” as provided under Section 202(a)(11) of the Investment Advisers Act of 1940 and corresponding state securities laws. The Site and Services are bona fide publications of general and regular circulation offering impersonalized investment-related information to users and/or prospective users (e.g., not tailored to the specific investment needs of current and/or prospective users). To the extent any of the content published as part of the Site or Services may be deemed to be investment advice, such information is impersonal and not tailored to the investment needs of any specific person.
  3. We will not evaluate your individual financial condition, investment portfolio, investment experience, age, income, tax bracket, risk tolerance, investment objectives or other similar factors (referred to herein as “Individual Financial Requirements”).
  4. The Site and Services are currently limited to the dissemination of impersonal investment-related information pertaining to SMTM  “technically-based” analyses, together with access to additional impersonal investment-related information and links. By its nature, technically-based analysis does not contemplate the user’s Individual Financial Requirements.
  5. The Site and Services do not offer and users do not receive initial or ongoing individual personalized investment advice, investment reporting, investment supervisory or investment management services, nor the ongoing review or monitoring of the user’s individual investment portfolio. Rather, the Site and Services are designed solely to provide users with a method to identify and evaluate potential opportunities and obtain information on market analysis, current events, trade methodology, and other related information. Therefore, each user hereby agrees that use of the Site or any Service is not a substitute for ongoing individual personalized advice from an investment professional of the user’s choosing.
  6. Each user hereby agrees that he/she/it should independently evaluate and determine whether to act upon any information provided through the Site or Services (including without limitation, individual “picks”, recommendations or trends) based on the user’s Individual Financial Requirements. Further, each user hereby acknowledges that neither SMTM nor any of its Affiliates will advise you personally concerning the nature, potential or suitability of any particular trend, security, portfolio of securities, transaction, investment strategy or other similar matter.
  7. Certain portions of the Site and certain Services (i.e. newsletters, articles, commentaries, etc.) may contain a discussion of, and/or provide access to, positions of SMTM or its Affiliates and/or their “picks,” trades, or recommendations. Due to various factors, including, but not limited to, changing market conditions, such position, discussion, pick or recommendation may only be valid for a specific moment in time (day, hour, minute or tick of the tape). Thus, each user hereby agrees to independently evaluate and determine whether to act upon any such information. Moreover, no user or prospective user should assume that any such discussion serves as the receipt of, or a substitute for, individual personalized advice from an investment professional of his/her/its choosing.
  8. You acknowledge that news, information and performance data available through the Site or any Service is supplied by sources believed to be reliable but that SMTM undertakes no responsibility to verify the accuracy or completeness of such information or to update such information. Further, the Site or Services may contain trades, recommendations, opinions, news or information which are incomplete or dated. As markets change continuously, previously published recommendations, news information and data may not be current and should not be relied upon.
  9. To the extent that the Site or any Service contains a “model portfolio”, such model portfolio is to be construed as developed based upon a particular investment strategy but not developed for any user’s Individual Financial Requirements. Further, the actual results of the portfolio, as well as a user’s actual results may differ substantially from the stated investment strategy.
  10. Past performance may not be indicative of future results. Therefore, no current or prospective user should assume that the future performance of any trend, pick, recommendation, specific investment, investment strategy, product or service made or referenced directly or indirectly through the Site or Services will be profitable or otherwise provide equal historical or anticipated performance level(s).
  11. Different types of currencies, securities and investments involve varying degrees of risk, and there can be no assurance that any specific currency, security, investment or investment strategy referenced directly or indirectly through the Site or Services will be suitable for a user’s and/or prospective user’s investment portfolio.
  12. You acknowledge and agree that the Site and Services may contain picks, recommendations or trends that may be different from those obtained through other portions of the Site or other Services and that SMTM or its Affiliates and third party service providers may, from time to time, have long and short positions in, or buy or sell the currencies, securities, or derivatives thereof, of companies referenced through the Site or Services and may take positions inconsistent with the views expressed through the Site or Services.
  13. You acknowledge and agree that certain SMTM Affiliates may discuss or recommend specific currencies, securities or investment strategies in which they or their firms have a position, and that they may trade for their own account. In cases where the position is held at the time of publication, SMTM  will endeavor to make appropriate disclosures. However, due to the short term nature of the investment and trading activities of such Affiliates, such disclosure may not be possible, or feasible. Therefore, you understand and agree that at the time of any transaction that you make, one or more of SMTM Affiliates may have an undisclosed position in the currencies or securities referenced. SMTM makes no representations regarding the strategies or individual currencies positions of any third party service provider.
  14. To the extent that any user or prospective user utilizes any investment “filtering software”, economic, financial or retirement “calculator” or similar device (collectively referred to as “Software”) contained within or linked to the Site or referenced in any Service, the user or prospective user acknowledges and understands that the information resulting from the use of any such Software should not be construed, in any manner whatsoever, as the receipt of personalized investment advice from SMTM, its affiliates or any third party service provider and should not be considered a substitute for individual personalized advice from an investment professional of his/her/its choosing.
  15. The actual results of any pick, recommendation, investment or investment strategy will vary depending on execution time, speed and quality, market liquidity, commissions and other fees, and general market conditions and volatility.
  16. SMTM and its Affiliates do not possess and do not desire any material non-public information regarding any currency or company. Such information will not be provided or accepted by SMTM or any of its Affiliates.
  17. SMTM and its Affiliates do not offer or provide investment implementation services.
  18. The Site and Services do not establish a fiduciary relationship.
  19. The publication of the Site or Services should not be construed by any user and/or prospective user as a solicitation to effect, or attempt to effect transactions in currencies or securities by any person or entity.
  20. SMTM may suggest affiliated or third party service providers through the Site or Services and/or provide user information to affiliated or third party service providers. SMTM may receive a fee from such affiliated or third party service providers. While SMTM may review the products and services of any such recommended affiliated or third party service provider, users and/or prospective users hereby agree to determine for themselves whether any such recommended service provider is appropriate for his/her/its individual circumstances prior to the engagement thereof. SMTM  does not make any representations or warranties as to the accuracy, timeliness, suitability, completeness, or relevance of any information prepared by any affiliated or unaffiliated third party service provider, whether linked to the Site or incorporated therein, and takes no responsibility therefor. All such information is provided solely for convenience purposes only and all users thereof should be guided accordingly.
  21. Third Party Service Providers and Information

The Site and/or Services may contain links, references or recommendations to third party services providers. Your use or purchase of any product or service provided by a third party service provider is governed by the terms, conditions and rules imposed by such third party service provider and not by SMTM Terms. By using any service you are acknowledging that you have reviewed all such terms, conditions and rules and agree to be bound by them. Further, you hereby agree to look only to such third party provider for the provision of such product or service or for satisfaction of any claim you may have related to such product or service. You acknowledge and agree that SMTM and its Affiliates shall not be held responsible for the legality, accuracy, or inappropriate nature of any third party product or service or for any loss or damages caused or alleged to have been caused by the use of such product or service.

The Site or Services may contain links, references or recommendations to information, and/or opinions of third parties. We do not control such third parties nor necessarily endorse any such information or opinions, nor have we reviewed or approved any such content. You acknowledge and agree that SMTM, and its Affiliates shall not be held responsible for the legality, accuracy, or inappropriate nature of any content, advertising, products, services, or information provided by any third party, nor for any loss or damages caused or alleged to have been caused by the use of or reliance on any such content.

You expressly acknowledge and agree that your use of any third party product, service, information or opinion is solely at your risk.

  1. Disclaimer of Warranties

The Site, Services, and any content, product, news, pick, recommendation, information or other data or service contained or referenced therein, or accessed through the Site or Service, is provided “as is” and without representations or warranties of any kind, either express or implied. To the fullest extent permissible pursuant to applicable law, SMTM and its Affiliates disclaim all warranties, express, implied or statutory, including, but not limited to, implied warranties of title, non-infringement, merchantability, and fitness for a particular purpose, and all warranties relating to the adequacy, accuracy or completeness of any information available through the Site or any Service.

SMTM and its Affiliates do not warrant that your use of the Site or Services will be uninterrupted, error-free, or secure, that defects will be corrected, or that the Site or Services are free of viruses or other harmful components. You acknowledge that you are responsible for obtaining and maintaining all telephone, computer hardware and other equipment needed to access and use Site and Services, and all charges related thereto. You assume complete and ultimate responsibility (and acknowledge and accept all risks) for your use of the Site and/or Services and your reliance on any picks, recommendations, news or other information directly or indirectly provided. No opinion, advice, or statement of SMTM or any of its Affiliates, whether made on the Site or as part of any Service or otherwise, shall create any warranty. You use of the Site and Services, and the picks, recommendations and other information and materials provided is entirely at your own risk.

You expressly acknowledge that picks, recommendations and other information and materials available through the Site or Services may contain inaccuracies or errors, or materials that violate the Terms and that unauthorized alterations could be made to the content available through the Site or Services by third parties. Although we attempt to ensure the integrity of the Site and Services, we make no guarantees as to the completeness or correctness of the Site or Services. Thus, you agree that, even when SMTM  has had an opportunity to remove or correct such erroneous content, SMTM shall have no liability to you (or anyone claiming through you) based upon such erroneous content. Further, you agree that SMTM  and its Affiliates shall not be liable for any delay or failure in performance resulting directly or indirectly from acts of nature, forces or causes beyond its reasonable control, including, without limitation, Internet failures, computer equipment failures, telecommunication equipment failures, other equipment failures, electrical power failures, strikes, labor disputes, riots, insurrections, civil disturbances, shortages of labor or materials, fires, floods, storms, explosions, acts of God, war, governmental actions, orders of domestic or foreign courts or tribunals, or non-performance of third parties.

  1. Indemnification

On behalf of yourself and your heirs, successor and assigns, you hereby agree to indemnify, defend and hold SMTM, its shareholders, and its employees and affiliates harmless from and against any and all claims, damages, losses, costs (including reasonable attorneys’ fees), or other expenses that arise directly or indirectly out of or from:

  1. Your use of the Site or any Service;
  2. Your decision to follow or act upon any trend, pick, recommendation or opinion received, contained or referenced in or through the Site or any Service or from any third party service provider;
  3. Any inaccurate, incomplete or erroneous information received, contained or referenced in or through the Site or any Service, whether or not SMTM had an opportunity to remove or correct such information;
  4. Your violation of these Terms; or
  5. Your violation of any third party service provider terms, conditions and rules and/or the rights of any third party.
  6. Limitation of Liability

On behalf of yourself and your heirs, successor and assigns, you hereby acknowledge and accept the limitations of the Site and Services, and agree, as a condition precedent to your access (or continued access) to the Site or Services, that neither SMTM nor its Affiliates and owners shall be liable or responsible to you (or anyone claiming through you) for any indirect, incidental, consequential, special, exemplary, punitive or other damages under any legal or equitable theory (including without limitation, contract, tort negligence, strict liability, statute, regulation, rule or other theory) arising out of or relating in any way to the Site or any Service and/or any trend, pick, recommendation, news, information or other content, product or service received or obtained through the Site or any Service, including without limitation any product, service or content from any third party service provided. Your sole remedy for dissatisfaction with the Site or any Service is to stop using it. The sole and exclusive maximum liability to SMTM and/or any of its Affiliates and owners in the aggregate for all damages, losses, and causes of action under any legal or equitable theory (including without limitation, contract, tort, negligence, strict liability, statute, regulation, rule or other theory) shall be the total amount actually paid SMTM, if any, for access to the Site or Services in the current calendar year in which the alleged damages were incurred.

  1. Term and Termination

You acknowledge that the term of your use of the Site or any Service is “at will” in the sole discretion of SMTM. Accordingly, you hereby agree that SMTM may, without prior notice to you, terminate your access to and use of the Site or any Service, with or without cause.

  1. Changes to the Terms of Use

Any changes to these terms and conditions will be notified to all clients by email.


  1. Membership Options & Cancellation Policy 

SMTM offers its products and services via the website. 

We reserve the right to refuse or cancel your order at any time for any reason including but not limited to: product or service availability, errors in the description or price of the product or service, errors in your order, or if fraud or an unauthorized or illegal transaction is suspected. We will not be held responsible or liable for any failure of a transaction to complete, or any resulting loss or damages to you.

Your obligations hereunder, including your obligation to pay amounts owed under these Terms for use of or access to our services or materials, including subscriptions, shall survive expiration or termination of these Terms and your cessation of use of the Services.


  1. Other

The provision of this Site and all Services, and performance of all agreement and covenants required by these Terms shall be deemed to be made without regard to its principals of conflict of laws. Accordingly, you hereby agree to submit to the personal and exclusive jurisdiction for any and all claims arising from your use of the Site or any Service. Those users who access the Site or Services from another jurisdiction hereby waive any jurisdictional, venue, or inconvenient forum objections to such courts. Further, all users hereby waive the right to a trial by jury for any claims arising out of their access or use of the Site or any Service. We reserve the right to limit the availability of the Service to any person, geographic area, or jurisdiction we so desire, at any time and in our sole discretion, and to limit the quantities of any such service or product that we provide. If any provision of these Terms is found to be unlawful, void, or for any reason unenforceable, then that provision shall be deemed modified only to the extent necessary to make such provision lawful and enforceable and if such provision cannot be so modified, severed from the Terms; provided that such modification or removal shall not affect the validity and enforceability of any remaining provisions. No waiver by either party of any breach or default hereunder shall be deemed to be a waiver of any preceding or subsequent breach or default. Any heading, caption or section title contained in the Terms is inserted only as a matter of convenience and in no way defines or explains any section or provision hereof.



Prices for our products are subject to change without notice.

We reserve the right at any time to modify or discontinue the Service (or any part or content thereof) without notice at any time.

We shall not be liable to you or to any third-party for any modification, price change, suspension or discontinuance of the Service.


Risk Disclaimer

Trading foreign exchange on margin carries a high level of risk, and is not suitable for all investors. Past performance is not indicative of future results. The high degree of leverage is dangerous and can work against you as well as for you. Before deciding to invest in foreign exchange or any market you should carefully consider your investment goals, level of experience, and risk tolerance. It is EXTREMELY LIKELY that you will sustain a loss of some or all of your initial investment and therefore you should not invest money that you cannot afford to lose. No representation is being made that any account will or is likely to achieve profits or losses. Past performance is not indicative of future results. Individual results vary and no representation is made that clients will or are likely to achieve profits or incur losses comparable to those that may be shown.


The Members Testimonials found on this website and on our social media accounts are ONLY from our REAL clients and students that have purchased our services, however, the statements of individuals are not to be construed as claims or representations of average earnings. We cannot, do not, and will not make any claims as to earnings, average, or otherwise. We do not track the typical results of our customers or verify the accuracy of publicly available student testimonials. We have performed no independent verification of the statements made by those individuals. Please do not assume that you will make those same income figures or experience. Additionally, some of them after tge video was created, received monetary compensation in order to place their video, review and face on the website. 


You acknowledge and agree that no promise or guarantee of success or profitability has been made between you and SMTM. Do your own research and talk to a professional financial planner in order to be aware of all the risks associated with foreign exchange trading and investing, and seek advice from an independent financial advisor before risking any capital.

*Everything on this site ( and it’s services are for educational purposes only and should not be taken as advice on how to invest your capital. Always speak with a professional financial planner or advisor before making any investment decisions.

 *Results or personal accounts of trading success or improvement may be based on simulated or hypothetical performance results that have certain inherent limitations. Also, because these trades have not actually been executed, these results may have under-or over-compensated for the impact, if any, of certain market factors, such as lack of liquidity. No representation is being made that any account will or is likely to achieve profits or losses similar to these being shown.

* NEVER take a trade based on what you see on this site or any services provided by, SMTM, and neither of them will be held responsible for any losses that occur in your account, emotional or medical trauma that you incur directly or indirectly from information provided by this site or its services. You and you alone are responsible for deciding if you are comfortable accepting the risk involved in Forex trading.

*The Foreign Exchange Market & Currency Trading in general, is highly volatile. Any information contained on this site, or which is used for educational purposes, may be changed without notification.

*By accessing this website, you agree that you understand this: Information contained in this product are not an invitation to trade any specific investments. Trading requires risking money in pursuit of future gain. That is your decision. Do not risk any money you cannot afford to lose. This document does not take into account your own individual financial and personal circumstances. It is intended for educational purposes only and NOT as individual investment advice. Do not act on this without advice from your investment professional, who will verify what is suitable for your particular needs & circumstances. Failure to seek detailed professional personally tailored advice prior to acting could lead to you acting contrary to your own best interests & could lead to losses of capital. 

SMTM, its owner or employees are NOT a financial broker/dealer or an investment advisor. You are responsible for your own investment and trading decisions. All information contained on our website, distributed via email, SMS text messaging or elsewhere should be independently verified and readers and subscribers/members should always conduct their own research and due diligence and consider obtaining professional advice before making any financial trading or investment decision. Owners, employees, and writers may hold financial positions that are discussed on our website, communicated via email, SMS text messaging or other mediums.

*The purchase, sale or advice regarding a currency can only be performed by a licensed Broker/Dealer. Neither SMTM nor any of its affiliates or associates involved in the production and maintenance of these products or this site, is a registered Broker/Dealer or Investment Advisor in any State or Federally-sanctioned jurisdiction. All purchasers of products referenced at this site are encouraged to consult with a licensed representative of their choice regarding any particular trade or trading strategy. No representation is being made that any account will or is likely to achieve profits or losses similar to those discussed on this website. The past performance of any trading system or methodology is not necessarily indicative of future results.


United States Government Required Disclosure – Commodity Futures Trading Commission (CFTC)

Futures and options trading has large potential rewards, but also large potential risk. You must be aware of the risks and be willing to accept them in order to invest in the futures and options markets. Do not trade with money you cannot afford to lose. This is neither a solicitation nor an offer to buy/sell futures or options. No representation is being made that any account will or is likely to achieve profits or losses similar to those discussed on this web site. The past performance of any trading system or methodology is not necessarily indicative of future results.



CFTC Rule 4.41 – Hypothetical or simulated performance results have certain limitations. Unlike an actual performance record, simulated results do not represent actual trading. Also, since the trades have not been executed, the results may have under-or-over compensated for the impact, if any, of certain market factors, such as lack of liquidity. Simulated trading programs in general are also subject to the fact that they are designed with the benefit of hindsight. No representation is being made that any account will or is likely to achieve profits or losses similar to those shown.


Privacy Policy 

Your privacy is important to SMTM. To reinforce our commitment to protect your privacy, we provide this notice explaining our online information practices and the choices you can make about the way your information is collected and used on Our Site. This policy summarizes the information, including personally identifiable information, that we collect through Our Site and how that information may be used. By using Our Site you consent to the collection and use of this information.

We reserve the right to change our privacy policy at any time. In the event we make changes to any of the terms or conditions of this privacy policy, we will incorporate those changes into this document so you will know what information is being collected and how that information is being used. We will undertake best efforts to notify you of any changes to this privacy policy utilizing the last email address you have provided to us; however, it is your responsibility to keep your email address current and to monitor this policy for any changes. Continued use of Our Site and/or our services shall constitute consent to this policy and any changes made hereto.

1.) Definitions and Interpretation

In this Policy the following terms shall have the following meanings:

“Account” means an account required to access and/or use certain areas and features of Our Site

“Cookie” means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in section 12, below;

“Our Site” means this website and all its subdomains

 “UK and EU Cookie Law” means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003 as amended in 2004, 2011 and 2015; and

“We/Us/Our” means SMTM

2.) What Does This Policy Cover?

This Privacy Policy applies only to your use of Our Site. It does not extend to any websites that are linked to from Our Site (whether We provide those links or whether they are shared by other users). We have no control over how your data is collected, stored or used by other websites and We advise you to check the privacy policies of any such websites before providing any data to them.

3.) Information We Collect

We may collect and use your IP address to help administer services on our website as well as to improve your user experience. We do not use your IP address to collect any personally identifiable information. Demographic and interest data is also collected at our Website. We use this data to tailor the information emailed to our customers and to display the content according to their preferences.

Some data will be collected automatically by Our Site (for further details, please see section 13 on Our use of Cookies (Our Cookie Policy is below), other data will only be collected if you voluntarily submit it and consent to Us using it for the purposes set out in section 5, for example, when signing up to receive training material, making a purchase etc. Depending upon your use of Our Site, We may collect some or all of the following data:

Full Name

Address, including street name, city/town, state and zip code

Email Address

Phone Number

Company Information


IP Address

Payment Information (Credit card/Debit card details)

Web Browser Type and Version

Operating System

URLs identifying your referring site and/or activity on Our Site

If you are purchasing products, we may use a third party provider such as a shopping cart to collect a credit card number and related payment information or alternative methods of payment. If you provide information on third party sites, the privacy policy and terms of service on those sites are applicable.

We may also collect information you provide about others, such as how you were referred to our website and programs.

4.) How we collect personal information

We collect personal information directly when you provide it to us, automatically as you navigate through the Sites, or through other people when you use services associated with the Sites.

We collect your personal information when you provide it to us when you complete membership registration and buy or provide items or services on our Sites, subscribe to a newsletter, email list, submit feedback, enter a contest, fill out a survey, or send us a communication.

5.) How We Use Information

We use the information collected to provide the best possible products and services to you and to ensure a positive experience with our company and website. This includes:

-Providing and managing your Account

-Providing and managing your access to Our Site

-Personalising and tailoring your experience on Our Site

-Supplying Our products and services to you

-Personalising and tailoring Our products and services for you

-Responding to communications from you

-Supplying you with email newsletters, alerts etc. that you have subscribed to

-Carrying out technical analysis to determine how to improve the Sites and services we provide;

-Monitoring activity on the Sites, e.g. to identify potential fraudulent activity and to ensure compliance with the user terms that apply to the Sites;

-Managing our relationship with you, e.g. by responding to your comments or queries submitted to us on the Sites or asking for your feedback or whether you want to participate in a survey;

-Managing our legal and operational affairs (including, managing risks relating to content and fraud matters)

If you no longer wish to receive emails from SMTM please contact us directly at .

If you provide your telephone number, you agree and acknowledge that you may receive telephone calls or text messages from us with information regarding new products and services, or upcoming events. If you do not wish to receive phone calls or text messages please notify us at .

6.) Sharing Information

Privacy matters are very important to us and all available resources and processes are implemented to make sure your information remains safe and secure. We do not sell, license, lease or otherwise disclose your personal information to any third party for any reason except as noted herein.

We may share personal information described above with our affiliates for business purposes, such as, but not limited to, servicing customers and informing customers about new products and services, and as permitted by applicable law. Our affiliates may include companies controlled or owned by SMTM as well as companies that have an ownership interest in our company. The information we share with affiliates may include any of the information described above, such as your name, address and email address. Our affiliates maintain the privacy of your information to the same extent SMTM does in accordance with this Policy.

Information may be shared with third parties that perform support services for SMTM such as non-affiliate companies that provide professional, legal, or accounting advice. Non-affiliated companies that assist us in providing services to you are required to maintain the confidentiality of such information to the extent they receive it and to use your personal information only in the course of providing such services, as directed by SMTM. We may also disclose information in response to legal requests, such as a court order or subpoena.

As we develop our business, we might sell, buy, restructure or reorganize our business or assets. In the event of a merger, consolidation, sale, liquidation or transfer of assets, SMTM may, in its sole and absolute discretion, transfer, sell or assign information collected, including without limitation, non-personal information and personal information, to one or more affiliated or unaffiliated third parties.

7.) Information you make public or give to others

This site may make chat rooms, forums, message boards, and/or news groups available to its users. Please remember that any information that is disclosed in these areas becomes public information and you should exercise caution when deciding to disclose your personal information.

If you make your personal information available to other people, we can’t control or accept responsibility for the way they will use or manage that data. There are lots of ways that you can find yourself providing information to other people, like when you post a public message on a forum thread, share information via social media, or make contact with another user whether via our Sites or directly via email. Before making your information publicly available or giving your information to anyone else, think carefully. If giving information to another user via our Sites, ask them how they will handle your information. If you’re sharing information via another website, check the privacy policy for that site to understand its information management practices as this privacy policy will not apply.

8.) How we keep your personal information secure

We store personal information on secure servers that are managed by us and our service providers, and occasionally hard copy files that are kept in a secure locations. Personal information that we store or transmit is protected by security and access controls, including username and password authentication, two-factor authentication, and data encryption where appropriate.

9.) How you can access your personal information

You can access some of the personal information that we collect about you by logging in to your account. You also have the right to make a request to access other personal information we hold about you and to request corrections of any errors in that data. You can also close the account you have with us for any of our Sites at any time. To make an access or correction request, contact our privacy champion using the contact details at the end of this policy.

10.) Marketing Choices regarding your personal information

Where we have your consent to do so (e.g. if you have subscribed to one of our e-mail lists or have indicated that you are interested in receiving offers or information from us), we send you marketing communications by email about products and services that we feel may be of interest to you. You can ‘opt-out’ of such communications if you would prefer not to receive them in the future by using the “unsubscribe” facility provided in the communication itself.

You also have choices about cookies, as described below. By modifying your browser preferences, you have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject cookies some parts of our Sites may not work properly in your case.

11.) How long we keep your personal information

We retain your personal information for as long as is necessary to provide the services to you and others, and to comply with our legal obligations. If you no longer want us to use your personal information or to provide you with our services, you can request that we erase your personal information and close your account. Please note that if you request the erasure of your personal information we will retain information from deleted accounts as necessary for our legitimate business interests, to comply with the law, prevent fraud, collect fees, resolve disputes, troubleshoot problems, assist with investigations, enforce the terms of service and take other actions permitted by law. The information we retain will be handled in accordance with this Privacy Policy.

12.) Cookies

When you visit our Sites, there’s certain information that’s recorded which is generally anonymous information and does not reveal your identity. If you’re logged into your account some of this information could be associated with your account. We’re talking about the following kinds of details:

-your IP address or proxy server IP address

-the domain name you requested

-the name of your internet service provider is sometimes captured depending on the configuration of your ISP connection

-the date and time of your visit to the website

-the length of your session

-the pages which you have accessed

-the number of times you access our site within any month

-the file URL you look at and information relating to it

-the website which referred you to our Sites

-the operating system which your computer uses.

Occasionally, we will use third party advertising companies to serve ads based on prior visits to our Sites. For example, if you visit our Sites, you may later see an advertisement for our products and services when you visit a different Site.

Each time your visit our website our servers automatically record your activity and information such as your IP address and/or the domain from which you are visiting. We also record which links on our webpage you click on or visit and any search terms you use. We use this data for website maintenance and technical administration. Your IP address is never linked with any personally identifiable information to identify you personally, except in the case of our investigation into a violation of the terms of use or alleged misconduct.

13.) Links to Other Websites

This site may contain links to third parties’ websites. Please note that we are not responsible for the collection, use, maintenance, sharing, or disclosure of data and information by such third parties. If you provide information on third party sites, the privacy policy and terms of service on those sites are applicable. Especially if the third party site is used in connection with a purchase of a product. We encourage you to read the privacy policies of websites that you visit before submitting personal information.

14.) When we need to update this policy

We will need to change this policy from time to time in order to make sure it stays up to date with the latest legal requirements and any changes to our privacy management practices.

When we do change the policy, we’ll make sure to notify you about such changes, where required. A copy of the latest version of this policy will always be available on this page.

15.) Our Commitment to Security and Confidentiality

Notwithstanding our commitment to security and confidentiality, the fact remains that no transmission over the internet or any wireless network provides complete security. In light of the inherent vulnerability, you acknowledge that: (a) there exists security and privacy limitations which are beyond our control; (b) there can be no guaranty of the security, integrity and privacy limitations related to information transmitted to us over the internet or through our website; and/or (c) outside interference through piracy cannot be controlled by us and as such, information and data transmitted may be viewed by unauthorized third parties.

16.) If you’re a user or visitor in the European Economic Area these rights also apply to you:

For the purposes of applicable EU data protection law (including the General Data Protection Regulation 2016/679 (the “GDPR”), we are a ‘data controller’ of your personal information.

You are also entitled to ask us to port your personal information (i.e. to transfer in a structured, commonly used and machine-readable format, to you), to erase it, or restrict its processing. You also have rights to object to some processing that is based on our legitimate interests, such as profiling that we perform for the purposes of direct marketing, and, where we have asked for your consent to process your data, to withdraw this consent as more fully described below.

These rights are limited in some situations – for example, we can demonstrate that we have a legal requirement to process your personal information. In some instances, this means that we may retain some data even if you withdraw your consent.

Where we require your personal information to comply with legal or contractual obligations, then provision of such data is mandatory: if such data is not provided, then we will not be able to manage our contractual relationship with you, or to meet obligations placed on us. In all other cases, provision of requested personal information is optional.

If you have unresolved concerns you also have the right to complain to data protection authorities. The relevant data protection authority will be the data protection authority of the country: (i) of your habitual residence; (ii) of your place of work; or (iii) in which you consider the alleged infringement has occurred.

17.) How you can contact us

If you have any questions about our privacy practices or the way in which we have been managing your personal information, please contact us at