The following describes the privacy considerations enacted by Think Alpha Securities LLC (“TAS”, “the Firm”) relating to the use of customer’s and website visitor’s personal information.
Like most website operators, TAS collects non-personally-identifying information of the sort that web browsers and servers typically make available, such as the browser type, language preference, referring site, and the date and time of each visitor request. TAS's primary purpose in collecting non-personally-identifying information is to better understand how visitors use its website. From time-to-time, TAS may release non-personally-identifying information in the aggregate, e.g., by publishing a report on trends in the usage of its website. TAS also collects potentially personally-identifying information like Internet Protocol (IP) addresses for logged in users and for users leaving comments on TAS posts. TAS only discloses logged-in user and commenter IP addresses under the same circumstances that it uses and discloses personally-identifying information as described below, except that blog commenter IP addresses are visible and disclosed to the administrators of the blog where the comment was left.
Gathering of Personally-Identifying Information
Certain visitors to Think Alpha Securities LLC’s website choose to interact with TAS in ways that require TAS to gather personally-identifying information. The amount and type of information that TAS gathers depends on the nature of the interaction. For example, TAS asks visitors who sign up for an account on www.ithinkalpha.com to provide an email address. In this case, TAS collects such information only insofar as is necessary or appropriate to fulfill the purpose of the visitor's interaction with TAS. TAS does not disclose personally-identifying information other than as described below. Visitors can always refuse to supply personally-identifying information, though doing so may prevent them from engaging in certain website-related activities. TAS has implemented Google Analytics Demographics and Interest Reporting and uses Google Analytics cookies and identifiers for the sole purpose of data analytics. If you do not want to participate in TAS’s Google Analytics data collection, you may download the Google Analytics Opt-out Browser add-on here: https://tools.google.com/dlpage/gaoptout.
Protection of Certain Personally-Identifying Information
Think Alpha Securities LLC discloses potentially personally-identifying and personally-identifying information only to those of its employees, contractors, and affiliated organizations that (i) need to know that information in order to process it on TAS's behalf or to provide services available at TAS's website, and (ii) that have agreed not to disclose it to others. Some of those employees, contractors and affiliated organizations may be located outside of your home country; by using TAS's website, you consent to the transfer of such information to them. Other than to its employees, contractors and affiliated organizations, as described above, TAS discloses potentially personally-identifying and personally-identifying information only when required to do so by law, or when TAS believes in good faith that disclosure is reasonably necessary to protect the property or rights of TAS, third parties or the public at large. If you are a registered user of Think Alpha Securities LLC’s website and have supplied your email address, TAS may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what's going on with TAS and our products. If you send TAS a request (for example via a support email or via one of its feedback mechanisms), TAS reserves the right to publish it in order to help TAS clarify or respond to your request or to help TAS support other users. TAS takes all measures reasonably necessary to protect against the unauthorized access, use, alteration or destruction of potentially personally identifying and personally-identifying information.
Potential Sale of Certain Non-Personally-Identifying Information
TAS gathers customers' non personally-identifiable demographic information (the “Data”) in a form that does not permit direct association with any specific individual. This Data includes the customers’ geographic location, gender, age range, income range, social media “friend” count or “followers” and level of education. This Data is appended to the customers’ investment and trading activity in order to create a marketing-data information product that may be used for any purpose. This includes selling the Data to financial services and/or other companies that typically use this Data in their businesses to evaluate and tailor their client relations programs and marketing efforts and better understand customer behavior and improve their products, services, and advertising.
TAS may (i) monitor use of TAS’ services to determine customer’s compliance with the terms of the services, (ii) utilize any customer information and data (including trade data) on a confidential basis in connection with TAS’ development of any products, strategies or services, (iii) anonymize and/or de-identify any customer information and data (including trade data) and aggregate that information and data with other information and data for any further use or purpose in a manner sufficient to protect the confidentiality of the customer’s order and trade data (including for distribution to the public), and (iv) use any information gathered by TAS in connection with providing the services as is required to comply with applicable Laws and Policies.
TAS may collect statistics about the behavior of visitors to its website. TAS may display this information publicly or provide it to others. However, TAS does not disclose personally-identifying information other than as described above.