This website is operated by T3I Pty Ltd. and its subsidiaries (collectively, “T3”). At T3 we are committed to protecting the privacy of the persons who visit or use our SPIKESTM Analytics website (the “Website”). Your personal data is collected for specified, explicit and legitimate purposes and not further processed in a manner that is incompatible with those purposes, in accordance with this Privacy Statement and applicable data protection laws to which T3 is subject. By using or accessing a T3 Website, registering with T3, and to the extent required or permitted by applicable law, you signify your acknowledgment and assent to T3 collecting and processing information about you in accordance with this Privacy Statement.. Please therefore take the time to read the entire Privacy Statement carefully.

Collection of Information

In general, you can visit our Website without providing any personal information. However, you may be asked for personal information if you voluntarily register to receive additional information or services from T3. Our voluntary Email Sign-Up form requests user personal information such as name, email address and company name. You can sign up to receive email notifications by submitting your email address and can unsubscribe at any time. We use a third party service provider for our email notification service and such service provider may not use, sell or otherwise share your personal information without our consent, which we do not provide to them. Additionally, when you visit our Website, T3 may automatically collect information about your computer, including the IP address. See “Use of cookies and log files” below. We may also obtain your personal data from third parties, including third-party partners, applications, advertising networks, government agencies, regulatory bodies, and other market research data companies and organizations. Your personal data may also be obtained for authentication and security purposes in accordance with applicable law.

Uses of Information

We will use any personal information that is submitted by you to provide information and services to you for the purposes stated on the Website in accordance with this Privacy Statement. This Privacy Statement applies, however, only to the information collected through the Website. It does not apply to the use of personal information collected through access to any electronic trading platforms used to trade any SPIKES products and related products, including but not limited to options, futures, and/or exchange-traded products (“ETPs,” collectively, “SPIKES”), whether provided through the Internet, electronically or by other means. Electronic trading platforms are only accessible to members of such platforms and to any other participants of the electronic trading platform who have entered into definitive agreements with electronic trading platform provider for such right of entry. Further, such definitive agreements’ terms stipulate the rights of each electronic trading platform to use personal information collected by the electronic trading platform from their members and participants and how such information will be collected and processed, not this Privacy Statement. As such, T3 does not provide access to nor does it permit for the facilitation of trading in SPIKES and you should contact your electronic trading platform provider for any information related to its privacy and the ability to trade SPIKES through their platform. As such, the information on the Website is meant to provide an introduction to SPIKES and other related products. The information presented is for general educational and informational purposes only and should not be interpreted as personalized investment advice. No statement made herein should be construed as a recommendation to buy or sell a security. Market participants and investors interested in learning more about the SPIKES products are encouraged to consult with a financial advisor and/or professional. Any information or views provided on this Website are current as of the date indicated, and are subject to change without notice. Any information provided on this Website is for information purposes only, and does not constitute any financial, legal, tax, investment or other advice. Where such statements are based on information provided by third parties, they are not guaranteed to be accurate or complete. Any graphs, charts, or graphics are used for illustrative purposes only and do not reflect any future event or future value or performance of any investment. Any products and services, including investment, trading or tax strategies, must be evaluated relative to each individual’s goals, objectives, and risk tolerance. In order to make any financial decisions that suit your own needs, you must conduct your own research and seek the advice of a licensed financial advisor and/or professional if necessary. T3 is not liable for any errors or omissions on this Website, or for any loss or damages suffered as a result of anything appearing on this Website. We may also anonymize your personal information and use it for other purposes, including for research and improvement of our Website or services.

Security

We exercise reasonable precautions to secure information provided to us by users of our Website. We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. We retain any information provided to us for the length of time that we have a user or other relationship with you and for such period of time thereafter as we are required to by governing regulatory authorities.

Access to and Disclosures of Information

T3 will only grant access to personal data on a need-to-know basis, and such access will be limited to the personal data that is necessary to perform the business function for which such access is granted. No authorization will be extended to access personal data on a personal basis.. We will not share your information with third parties other than with our service providers unless we are required to do so by law or as requested by a governing regulatory authority, or when we believe that disclosure is necessary to protect our rights, your rights, the rights of others as required by applicable law and to maintain the integrity of our business operations in accordance with our policies. We will share information with regulators, government authorities, and third parties where we believe it is necessary to comply with a court order, subpoena, or regulatory request. We may disclose information when such disclosures will protect our rights or will assist in the enforcement of our Terms of Use or will protect your security. We also may disclose information to support the detection of, prevention of, or response to fraud or intellectual property infringement. As we grow as a company, we might become involved in transactions with third parties where we or they acquire or buy other businesses or assets. Also, we may participate in the negotiation or completion of a merger or sale involving all or a portion of T3’s operations, or a corporate reorganization or stock sale or other change in corporate control. In such transactions, customer information generally is one of the shared or transferred business assets. We may share or transfer any information we have about you to a third party in such a transaction as an asset or for the purposes of such third parties carrying on our business in relation to the continued provision of our services to you as described in this Privacy Statement. We may also share your information with our attorneys, banks, auditors and advisors to answer a governmental inquiry or requirement and/or to accomplish a contemplated transaction.

Links to Third-Party Websites

Our Website may provide links to other third-party websites. Neither T3 nor its affiliated entities endorse any advice, goods or services offered by third-parties. We have not verified the privacy policies applicable to third-party websites, nor have we determined what actions such parties will take regarding the privacy of visitors. In no event shall T3 or its affiliated entities be responsible for any third-party content, policies or actions. Except as required by applicable law, we will not provide any of your personal information to these third parties without your consent. We encourage you to read the privacy statements of other linked third-party websites when you leave our Website. This Privacy Statement applies only to information collected by our Website.

Use of Cookies and Log Files

When you visit our Website, T3 and third party service providers may automatically collect information about your computer, including the IP address. T3 also may use cookies or other technology such as log files to gather anonymous information regarding usage of the Website to help T3 improve its Website content, usability, security and functionality, as well as to assist T3 in determining user-browsing patterns. This information may be combined with other information you provide to us. Visitors to the Website can set their browsers to (a) prompt before accepting a cookie; (b) accept cookies automatically; or (c) reject all cookies. If you choose not to accept cookies from the Website, you may not be able to access and use all or part of the Website.

Choice/Opt-Out

If you choose to correct, update or delete personal information previously provided, T3 will endeavor to correct, update or remove the personal information in our database as soon as reasonably practicable. Please note that T3 may need to retain certain information for recordkeeping or other purposes as permitted or required by applicable law. You may also choose to unsubscribe from any T3 email lists. You can make requests related to previously provided personal information or T3 email lists by visiting T3 Email Subscriptions. You may contact support by emailing sho@t3index.com or mwood@triple3p.com should you have a question about making your subscription change request.

Data Subject Rights of California Residents

T3 is committed to protecting the privacy of T3 customers in California and their personal data in accordance with the California Consumer Privacy Act of 2018 (“CCPA”) and California Civil Code Section 1798.83 Shine the Light Law (“STL”). T3 shall comply with all requirements of the CCPA and STL alongside the terms of T3’s privacy policy described herein. Where policy requirements differ between T3’s existing privacy policies and the requirements of the CCPA and/or STL, T3 will adhere to any additional obligations or higher standards of protection enforced by these laws for California residents and their data. T3 subscribers and customers who are residents of California may request certain information about our disclosure of personal data and information to third parties for direct marketing purposes. To make such a request, please contact us at sho@t3index.com with “Request for California Privacy Information” on the subject line and in the body of your message. We will comply with your request within thirty (30) days or as otherwise required by the statute.

Information for EU Users and Notice to Non-US Users

We must have a legal basis to use, collect and process personal information under EU Privacy Laws. In most cases the legal bases for our processing, under EU law, will be one of the following:

(a) to fulfil our contractual obligations to you;
(b) to comply with our legal and/or regulatory obligations; and/or
(c) to meet our legitimate interests under the appropriate safeguards to protect your privacy interests, including:
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• to understand how you use our services and to enable us to use this knowledge to improve our products and services and to develop new ones,
• to communicate with you about the products and services that you use or we offer • to maintain our accounts and records, or
• to assess patterns of use.

We may obtain your consent to collect and use certain types of personal information when we are required to do so by law such as with respect to our use of cookies and tracking technologies. If we ask for your consent to process your personal information, you may withdraw your consent at any time by contacting us in accordance with the instructions set forth under “Choice/Opt-Out” above.

We may also anonymize your personal information and use it for other purposes. For example, we may prepare aggregated reports about how users interact with the Website for market or other research or to improve our Websites or services.

T3 processes and stores personal information in the United States, which may not have the same level of data protection as your home country.

Use of Sites By Children

None of our Sites are targeted for use by children under the age of eighteen. We do not target any of our products or services or Site content/features for use by children of such age.

Changes in this Privacy Statement

T3 reserves the right to modify this Privacy Statement at any time, so please review it frequently. If we decide to change our privacy policy, we will post those changes to this Privacy Statement, the homepage, and other places we deem appropriate so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it. If we make material changes to this policy, we will notify you here, by email, or by means of a notice on our home page.

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