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:

2.2 Information We Collect Automatically

When you access our Services, we automatically collect:

• Device type and operating system
• IP address
• Browser type and version
• Access times and dates
• Pages viewed and features used
• Clickstream data

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
• Analytics Cookies: Help us understand visitor interactions
• Performance Cookies: Measure and improve Service performance

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

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

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
• 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 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

5. Data Security

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

Note: 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. Your Rights and Choices

6.1 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.

6.2 Data Deletion

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

6.3 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.

6.4 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.

7. California Privacy Rights (CCPA/CPRA)

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: Request information about categories of personal information collected
• Right to Delete: Request deletion of personal information, subject to exceptions
• Right to Correct: Request correction of inaccurate personal information
• Right to Opt-Out: Opt out of the "sale" or "sharing" of personal information
• Right to Non-Discrimination: We will not discriminate against you for exercising your rights

8. European Privacy Rights (GDPR)

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

• 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 Lodge a Complaint: File a complaint with a supervisory authority

9. Data Retention

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

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).

10. 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 at privacy@surgeoptions.com.

11. Changes to This Privacy Policy

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.

For material changes, we will provide notice through email notification, prominent notice on our website, or in-app notification.

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

12. Contact Information

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

Response Time: We aim to respond to all inquiries within 30 days.