Last Updated: January 18, 2019
General Data Protection Regulation (GDPR)
We are a Data Controller of your information.
- You have given ToledoTrade, a division of Gar Wood Securities, LLC permission to do so.
- Processing your personal information is in ToledoTrade’s legitimate interests.
- ToledoTrade, a division of Gar Wood Securities, LLC needs to comply with the law.
If you are a resident of the European Economic Area (EEA), you have certain data protection rights. If you wish to be informed what Personal Information we hold about you and if you want it to be removed from our systems, please contact us.
In certain circumstances, you have the following data protection rights:
- The right to access, update or to delete the information we have on you.
- The right of rectification.
- The right to object.
- The right of restriction.
- The right to data portability
- The right to withdraw consent
Information We Collect
ToledoTrade collects and processes Personal Information from you. This may include, among other things, information:
- provided during the ToledoTrade account application process or during use of any of ToledoTrade’s website applications (for example, your name, email address, telephone number, birth date, tax ID number, investment objectives, etc.);
- acquired as a result of the transactions you conduct through the ToledoTrade systems or in connection with services offered by ToledoTrade;
- received from consumer-reporting agencies;
We may use your Personal Information for the following purposes (“Permitted Purposes”):
- To provide you with brokerage and other services available on our platforms, and/or to deal with any requests or inquiries you may have;
- To pursue legitimate interests, including to carry out, monitor and analyze our business or operations;
- To conduct our recruiting processes;
- To contact you (unless you tell us that you prefer us not to) regarding features and functionality that may be of interest to you;
- To enter into or carry out contracts of various kinds;
- To conduct monitoring by us or any other person on our behalf using various methods, including: (i) the use of “intelligent” automated monitoring tools; or (ii) through random monitoring of systems, for example systematically via electronic communication recording tools; (iii) specific monitoring of systems for example in relation to investigations, regulatory requests, subject access requests, litigation, arbitration or mediation or; (iv) data tracking, aggregation and analysis tools that pull data from various disparate data sources to draw linkages and/or detect behavioral patterns, interactions or preferences for analysis (including predictive analysis); and/or (v) using other similar monitoring technology that may become available from time to time;
- To comply with applicable laws or regulations in any country;
- For any other purpose for which your Personal Information was provided to us.
We may process your Personal Information for the following purposes after obtaining your express consent where legally required:
- To communicate with you through the channels you have approved to keep you up to date on the latest developments, announcements and other information about ToledoTrade services, products and technologies;
- To conduct customer surveys, marketing campaigns, market analysis, or promotional activities;
- To collect information about your preferences to create a user profile to personalize and foster the quality of our communication and interaction with you (for example, by way of newsletter tracking or website analytics).
ToledoTrade follows a standard procedure of using log files. These files log visitors when they visit websites. All hosting companies do this and a part of hosting services’ analytics. The information collected by log files include internet protocol (IP) addresses, browser type, Internet Service Provider (ISP), date and time stamp, referring/exit pages, and possibly the number of clicks. These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users’ movement on the website, and gathering demographic information.
Cookies and Web Beacons
Like any other website, ToledoTrade uses ‘cookies’. These cookies are used to store information including visitors’ preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users’ experience by customizing our web page content based on visitors’ browser type and/or other information.
You can learn how to manage cookies on your web browser by following your browser documentation.
Note that ToledoTrade has no access to or control over these cookies that are used by third-party advertisers.
Third Party Privacy Policies
You can choose to disable cookies through your individual browser options. To know more detailed information about cookie management with specific web browsers, it can be found at the browsers’ respective websites.
Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.
ToledoTrade does not knowingly collect any Personal Identifiable Information from children under the age of 13. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.
Updating your Personal Information
If any of the Personal Information that you have provided to us changes, for example if you change your email address or if you wish to cancel any request that you have made of us, please let us know by contacting ToledoTrade Customer Service through the ToledoTrade website at www.toledotrade.com/support/. We will not be responsible for any losses arising from any inaccurate, inauthentic, deficient or incomplete Personal Information that you provide to us.