Privacy Policy

1. INTRODUCTION

SurgeOptions ("Company," "we," "us," or "our") is committed to protecting your privacy and safeguarding your personal information. This Privacy Policy describes how we collect, use, disclose, and protect information about you when you access or use our website, platform, applications, and services (collectively, the "Services").

By accessing or using our Services, you acknowledge that you have read, understood, and agree to the practices described in this Privacy Policy. If you do not agree, you should not access or use our Services.

This Privacy Policy applies to all users of our Services, including traders, visitors, and any other individuals who interact with our platform.

2. INFORMATION WE COLLECT

2.1 Information You Provide Directly

We collect information you voluntarily provide when registering, participating in programs, making purchases, or communicating with us:

Account Registration Information:

• Full legal name
• Email address
• Phone number
• Mailing address
• Date of birth
• Username and password

Identity Verification Information:

• Government-issued identification (passport, driver's license, national ID)
• Proof of address documents
• Social Security Number or Tax Identification Number
• Photographs or selfies for verification

Financial Information:

• Payment card details
• Bank account information
• Billing address
• Transaction history (purchases and payouts)

Tax Information:

• W-9, W-8BEN, or equivalent tax forms
• Related tax documentation

Trading Experience Information:

• Trading experience and history
• Investment objectives
• Risk tolerance
• Financial situation

2.2 Information We Collect Automatically

When you access our Services, we automatically collect:

Device Information:

• Device type and operating system
• Unique device identifiers
• Browser type and version
• Screen resolution
• Mobile network information

Log and Usage Data:

• IP address
• Access times and dates
• Pages viewed and features used
• Clickstream data
• Referring and exit URLs

Trading Activity Data:

• All trading activity in your accounts
• Orders placed and executions
• Positions held
• Account balances
• Profit and loss data
• Risk metrics and performance statistics

2.3 Cookies and Tracking Technologies

We use cookies, pixel tags, web beacons, and similar technologies to collect information about your activities:

• Essential Cookies: Required for basic functionality (session maintenance, preferences)
• Analytics Cookies: Help us understand visitor interactions through anonymous data collection
• Performance Cookies: Measure and improve Service performance
• Advertising Cookies: Deliver relevant advertisements and measure campaign effectiveness

Managing Cookies: You can manage cookie preferences through browser settings. Disabling certain cookies may affect functionality.

2.4 Information from Third Parties

We may receive information from:

• Identity Verification Services: KYC/AML providers for identity verification and fraud prevention
• Payment Processors: Transaction information from payment service providers
• Marketing Partners: Information from advertising networks and analytics providers
• Public Sources: Social media profiles and public records
• Referral Partners: Information about referrals from affiliates

3. HOW WE USE YOUR INFORMATION

3.1 Providing and Improving Services

• Creating, maintaining, and administering your account
• Processing transactions, subscriptions, and payouts
• Evaluating trading performance and funding eligibility
• Providing customer support
• Analyzing usage patterns to improve Services
• Personalizing your experience

3.2 Security and Compliance

• Verifying identity and conducting KYC/AML checks
• Detecting, preventing, and investigating fraud and illegal activities
• Enforcing Terms of Service and Program Rules
• Complying with legal obligations (tax reporting, regulatory requirements)
• Protecting platform security and data integrity

3.3 Communications and Marketing

• Sending transactional communications (account, orders, payouts)
• Sending promotional communications (with consent where required)
• Delivering targeted advertising
• Conducting surveys and research

3.4 Analytics and Research

• Analyzing trading patterns and performance metrics
• Conducting statistical analysis and generating reports
• Developing and training machine learning models
• Research and development of new products and services

3.5 Legal Bases for Processing (where applicable)

We process personal information based on:

• Contract Performance: To provide Services you've requested
• Legitimate Interests: For business operations, security, and improvement
• Legal Compliance: To meet legal and regulatory obligations
• Consent: Where you have provided explicit consent

4. HOW WE SHARE YOUR INFORMATION

4.1 Service Providers

We share information with third-party service providers who perform services on our behalf:

• Cloud hosting and infrastructure providers
• Payment processors and financial institutions
• Identity verification and KYC/AML providers
• Customer support platforms
• Analytics and marketing services
• Email and communication services

These providers are contractually obligated to protect your information and use it only for specified purposes.

4.2 Execution Partners

We share necessary information with brokers, dealers, clearing firms, and technology providers who execute and clear trades under the Program.

4.3 Business Transfers

In connection with any merger, acquisition, reorganization, sale of assets, or bankruptcy, your information may be transferred to the acquiring entity.

4.4 Legal Requirements

We may disclose information:

• To comply with applicable laws, regulations, or legal processes
• To respond to lawful requests from public authorities
• To protect our rights, privacy, safety, or property
• To enforce our Terms of Service
• To investigate potential violations

4.5 With Your Consent

We may share information for purposes not described here with your explicit consent.

4.6 Aggregated or De-identified Data

We may share aggregated or de-identified information that cannot reasonably identify you for any purpose, including research, analytics, and marketing.

5. DATA RETENTION

5.1 Retention Periods

We retain personal information for as long as necessary to:

• Provide Services and maintain your account
• Comply with legal and regulatory obligations
• Resolve disputes and enforce agreements
• Support business operations and record-keeping

5.2 Account Data

Account information is retained for the duration of your account and for a period thereafter as required by law or business necessity (typically 5-7 years for financial records).

5.3 Trading Data

Trading activity data may be retained indefinitely for compliance, analytics, and research purposes.

5.4 Deletion Requests

Upon verified deletion requests, we will delete or anonymize your personal information except where retention is required by law or legitimate business purposes.

6. DATA SECURITY

6.1 Security Measures

We implement appropriate technical and organizational measures to protect your information:

Technical Safeguards:

• Encryption of data in transit and at rest (TLS/SSL, AES-256)
• Secure server infrastructure with firewalls and intrusion detection
• Multi-factor authentication options
• Regular security assessments and penetration testing
• Access controls and authentication requirements

Organizational Safeguards:

• Employee training on data protection
• Confidentiality agreements
• Limited access on a need-to-know basis
• Incident response procedures
• Regular policy reviews and updates

6.2 No Guarantee of Security

Despite our efforts, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your information. You are responsible for maintaining the confidentiality of your account credentials.

6.3 Breach Notification

In the event of a data breach affecting your personal information, we will notify you and relevant authorities as required by applicable law.

7. YOUR RIGHTS AND CHOICES

7.1 Access and Correction

You may access and update your account information through the Dashboard or by contacting us. You have the right to request a copy of the personal information we hold about you.

7.2 Data Portability

Where applicable, you may request your personal information in a structured, commonly used, machine-readable format.

7.3 Deletion

You may request deletion of your personal information, subject to our retention obligations and legitimate business interests.

7.4 Restriction of Processing

You may request that we restrict processing of your personal information in certain circumstances.

7.5 Objection to Processing

You may object to processing of your personal information based on legitimate interests, including profiling and direct marketing.

7.6 Withdrawal of Consent

Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing.

7.7 Communication Preferences

Marketing Communications: You may opt out of promotional emails by clicking "unsubscribe" or adjusting account preferences. Note that you cannot opt out of transactional communications.

Push Notifications: You may disable push notifications through device settings.

7.8 Do Not Track

Our Services do not currently respond to "Do Not Track" signals. We may continue to collect information as described regardless of such signals.

7.9 Exercising Your Rights

To exercise your rights, contact us at privacy@surgeoptions.com. We may require identity verification before processing requests. We will respond within the timeframes required by applicable law.

8. INTERNATIONAL DATA TRANSFERS

8.1 Transfer of Information

Your information may be transferred to and processed in countries other than your country of residence, including the United States, where data protection laws may differ.

8.2 Safeguards

When transferring personal information internationally, we implement appropriate safeguards:

• Standard contractual clauses approved by relevant authorities
• Binding corporate rules
• Certification mechanisms where applicable
• Your explicit consent where required

8.3 European Users

For users in the European Economic Area (EEA), United Kingdom, or Switzerland, we comply with applicable data transfer requirements under GDPR and equivalent laws.

9. CHILDREN'S PRIVACY

Our Services are not directed to individuals under 18 years of age. We do not knowingly collect personal information from children under 18. If we learn we have collected information from a child under 18, we will delete it promptly. If you believe we have collected information from a child, please contact us immediately.

10. THIRD-PARTY LINKS AND SERVICES

10.1 Third-Party Websites

Our Services may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices of these third parties. We encourage you to read their privacy policies.

10.2 Third-Party Integrations

We may integrate with third-party services (payment processors, analytics providers, etc.). Your interactions with these services are governed by their respective privacy policies.

10.3 Social Media Features

Our Services may include social media features. Your interactions with these features are governed by the privacy policies of the social media platforms.

11. CALIFORNIA PRIVACY RIGHTS (CCPA/CPRA)

11.1 California Residents

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: You may request information about categories of personal information collected, sources of collection, purposes for collection or sale, categories of third parties with whom we share, and specific pieces of personal information collected.
• Right to Delete: You may request deletion of personal information, subject to exceptions.
• Right to Correct: You may request correction of inaccurate personal information.
• Right to Opt-Out of Sale/Sharing: You may opt out of the "sale" or "sharing" of personal information. Note: We do not "sell" personal information in the traditional sense.
• Right to Limit Use of Sensitive Personal Information: You may limit certain uses of sensitive personal information.
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights.

11.2 Exercising California Rights

To exercise your rights, contact us at privacy@surgeoptions.com. We may verify your identity before processing requests.

11.3 Authorized Agents

You may designate an authorized agent to submit requests on your behalf. We may require verification of agent authority.

11.4 Categories of Information

In the preceding 12 months, we have collected the following categories of personal information:

• Identifiers (name, email, phone, address, IP address)
• Financial information (payment details, transaction history)
• Commercial information (purchase history, trading activity)
• Internet activity (browsing history, platform interactions)
• Geolocation data
• Professional information (trading experience)
• Sensitive personal information (government IDs, SSN for verification)

12. EUROPEAN PRIVACY RIGHTS (GDPR)

12.1 EEA, UK, and Swiss Residents

If you are located in the European Economic Area, United Kingdom, or Switzerland, you have rights under the General Data Protection Regulation (GDPR) or equivalent laws:

• Right of Access: Obtain confirmation of processing and access to your data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion ("right to be forgotten")
• Right to Restriction: Restrict processing in certain circumstances
• Right to Data Portability: Receive data in a portable format
• Right to Object: Object to processing based on legitimate interests
• Right to Withdraw Consent: Withdraw consent at any time
• Right to Lodge a Complaint: File a complaint with a supervisory authority

12.2 Data Controller

SurgeOptions acts as the data controller for personal information collected through the Services.

12.3 Legal Bases

We process personal information based on:

• Performance of a contract
• Compliance with legal obligations
• Legitimate interests (security, fraud prevention, service improvement)
• Your consent

12.4 Contact for European Inquiries

For GDPR-related inquiries, contact our Data Protection contact at: privacy@surgeoptions.com

13. OTHER STATE AND REGIONAL PRIVACY LAWS

13.1 Virginia, Colorado, Connecticut, Utah, and Other U.S. States

Residents of states with comprehensive privacy laws (Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, etc.) may have similar rights to those described for California residents. Contact us to exercise your rights.

13.2 Canada

Canadian residents may have rights under PIPEDA or provincial privacy laws. Contact us for information about exercising your rights.

13.3 Other Jurisdictions

We strive to comply with applicable privacy laws in all jurisdictions where we operate. Contact us for information specific to your location.

14. CHANGES TO THIS PRIVACY POLICY

14.1 Updates

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. We will post the updated Privacy Policy with a new "Last Updated" date.

14.2 Notification

For material changes, we will provide notice through:

• Email notification to the address associated with your account
• Prominent notice on our website or Dashboard
• In-app notification

14.3 Continued Use

Your continued use of the Services after the effective date of any changes constitutes your acceptance of the updated Privacy Policy.

15. CONTACT INFORMATION

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us:

16. ADDITIONAL DISCLOSURES

16.1 Automated Decision-Making

We may use automated decision-making, including profiling, for:

• Fraud detection and prevention
• Risk assessment
• Trading performance evaluation
• Account eligibility determinations

You may have the right to request human review of automated decisions that significantly affect you.

16.2 Sensitive Personal Information

We collect sensitive personal information (government IDs, SSN, financial data) solely for:

• Identity verification and KYC/AML compliance
• Tax reporting obligations
• Processing transactions and payouts

We do not use sensitive personal information for advertising or profiling.

16.3 Financial Incentives

We may offer promotions, discounts, or other incentives that involve collection or use of personal information. Terms will be disclosed at the time of the offer.

17. GLOSSARY

• Personal Information: Information that identifies, relates to, or could reasonably be linked to you or your household.
• Sensitive Personal Information: Categories like government IDs, financial account information, precise geolocation, and other information subject to heightened protection.
• Processing: Any operation performed on personal information (collection, storage, use, disclosure, deletion).
• Data Controller: Entity that determines purposes and means of processing personal information.
• Data Processor: Entity that processes personal information on behalf of a controller.
• Cookies: Small text files stored on your device to enhance functionality and collect usage information.