Privacy Policy & Terms | Credit Spread Trading

Privacy & Terms

Credit Spread Trading Privacy Policy & Terms
Effective date: March 19, 2020

Credit Spread Trading takes protecting your online privacy seriously and complies with all U.S. regulations relevant to email practices, data collection, data management and data and information protection.

Furthermore, Credit Spread Trading, where applicable, abides by those regulations of foreign countries which may impact the company’s subscribers or customers.

This Privacy Policy provides our views and practices concerning privacy, personal data, and how they may pertain to you as a user of our website(s).

Credit Spread Trading, LLC (“us”, “we”, or “our”) operates the following websites (the “Service”). This Privacy Policy acts as an umbrella to all websites owned and operated by Credit Spread Trading, LLC, including but not limited to: 

www.creditspreadtrading.com.

The Credit Spread Trading Privacy Statement explains our views and practices concerning privacy, and how they may pertain to you as a user of our website(s), products or services.

This page informs you of our policies regarding the collection, use, and disclosure of personal data when you use our Service and the choices you have associated with that data.

We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions, accessible from www.creditspreadtrading.com

Information We Collect and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Types of Data Collected

Personal Data

While using our Service, we may ask you to provide us with certain personally identifiable information that can be used to contact or identify you (“Personal Data”). Such information may include, but is not limited to:

  • First name and last name
  • Email address
  • Phone number
  • Business name
  • Website URL
  • Address, State, Province, ZIP/Postal code, City
  • Any personal data you post on our website
  • Data about how you use our websites, products or subscription services
  • Technical data such as your IP address, your login data, details about your browser, time zone settings and other technology on the device you use to access our website
  • Your marketing and communication preferences
  • Any information that you directly provide to us whether through email, our contact form(s), over the phone, or otherwise
  • Cookies and Usage Data
  1. We do not collect any data unnecessary to the furtherance of our relationship with you.
  2. We do not collect nor store your personal data without your consent. Your consent is considered explicit any time:
    1. You provide your email address to one of our web-based forms.
    2. You access, by way of logging in to, a product or service you have purchased from Credit Spread Trading.
    3. You purchase a product or service from Credit Spread Trading.
  3. We do not rent, sell or share your personal data with any third-party other than those identified within the scope of this privacy policy and having legitimate reason for inclusion.
  4. Any data collected may be removed at your request at any time by emailing our support team at info@creditspreadtrading.com.
  5. At any time, should you choose not to receive email from Credit Spread Trading data will be removed from our systems within a reasonable period even though we may no longer communicate by email with you.
  6. We may maintain records of such requests for a period of time to ensure compliance with US and EU or other country-specific laws relating to email communication.

In most cases where we ask for email address, the purpose is for the following:

  • To provide email content, including articles, videos, webinars or offers for Credit Spread Trading products and services.
  • To explicitly determine your interest in a specific offer, product or service and to provide follow-up content to said offer, product or service.
  • To provide email content from other publishers or advertisers without disclosing your personal information to such publishers or advertisers.
  • To maintain your access to subscription-based products or services which you may choose to purchase from Credit Spread Trading.

If we collect full data and information from you on an order form for a product or service offered by Credit Spread Trading, that data is for credit card validation and approval purposes, including but not limited to: address verification, zip code verification, fraud prevention and approval of purchase request, which is performed by a third-party credit card processing firm.

  • Credit Spread Trading does not store your credit card data on servers or databases it owns.

We may use your Personal Data to contact you with newsletters, marketing or promotional materials and other information that may be of interest to you. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us

Usage Data

We may also collect information how the Service is accessed and used (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookies Data

We use cookies and similar tracking technologies to track the activity on our Service and hold certain information.

Cookies are files with small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from a website and stored on your device. Tracking technologies also used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service.

You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

Examples of Cookies we may use:

  • Session Cookies. We use Session Cookies to operate our Service.
  • Preference Cookies. We use Preference Cookies to remember your preferences and various settings.
  • Security Cookies. We use Security Cookies for security purposes.

Use of Data

Credit Spread Trading, LLC uses the collected data for various purposes:

  • To provide and maintain our website(s), product(s) or subscription service(s)
  • To notify you about changes to our Service
  • To allow you to participate in interactive features of our Service when you choose to do so
  • To provide customer support
  • To gather analysis or information to help Credit Spread Trading improve our website(s), product(s), service(s).
  • To monitor the usage of our website(s), product(s), service(s).
  • To detect, prevent and address technical issues of our website(s), product(s), service(s).
  • To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Legal Basis for Processing Personal Data Under General Data Protection Regulation (GDPR)

If you are from the European Economic Area (EEA), Credit Spread Trading LLC’s legal basis for the collection and use of personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it.

Credit Spread Trading, LLC may process your Personal Data because:

  • We need to perform a contract with you in the form of any product or service or subscription service you purchase or any information which you have legally requested or that Credit Spread Trading has offered to you.
  • You have given us permission to do so by way of providing your consent to receive information by way of email.
  • The processing is in our legitimate interests and is not overridden by your rights
  • For payment processing purposes
  • To comply with the law

Retention of Data

Credit Spread Trading, LLC will retain your Personal Data only for as long as is necessary for the purposes of this or any future Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

Credit Spread Trading, LLC will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer time periods.

Transfer of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

Credit Spread Trading, LLC will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.

Disclosure of Data

Business Transaction

If Credit Spread Trading, LLC is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Credit Spread Trading, LLC may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).

Legal Requirements

Credit Spread Trading, LLC may disclose your Personal Data in the good faith belief that such action is necessary to:

  • To comply with a legal obligation
  • To protect and defend the rights or property of Credit Spread Trading, LLC
  • To prevent or investigate possible wrongdoing in connection with the Service(s)
  • To protect the personal safety of users of the Service or the public
  • To protect against legal liability

Security of Data

We take reasonable precautions to ensure the security of your data, it is neither realistic nor possible to guarantee absolute security of data transmission as every transmission requires usage of third-party networks, servers, databases and software.

General Data Protection Regulation (GDPR): Your Data Protection Rights

While the intent of our Privacy Policy is to comply with certain laws, we view privacy seriously enough that we extend our Data Protection and Privacy policy globally, regardless of your locale.

If you are a citizen of a European Union member state, you have certain data protection rights which must be set forth explicitly.

Credit Spread Trading extends these rights across all of its services, websites, products, subscriptions and to all users who choose to interact with Credit Spread Trading. Credit Spread Trading, LLC will take reasonable steps to allow you to correct, amend, delete, or limit the use of your Personal Data.

If you wish to be informed what Personal data 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 and the right to know what information we maintain. You also have the right to withdraw your consent for Credit Spread Trading to maintain your data, except in instances of purchase data which information must be maintained to comply with state and federal tax laws.

We control and process your data through a third-party CRM software vendor: MailChimp, who is already compliant with necessary laws and whose privacy policy may be viewed here at  https://mailchimp.com/legal/privacy/

  • We use this data to keep track of emails we send to you and emails you do or do not open to assist us in delivering more useful content to you.
  • We maintain a record of certain links you may follow.
  • We maintain a record of your access to your subscription services, including but not limited to frequency of logins, expiration date(s) of services and other data related to management of your account as a customer.
  • We maintain a record of your purchases and subscriptions, including but not limited to date of purchase, amount of purchase, number of purchases, specific product or service purchased, dates of expiration of services and other data necessary to providing reasonable service to our customers.
  • You can ask to know what data we are collecting at any time by emailing our customer support team. They will respond within 30 days with an accounting of data we have on file for you.
  • You can choose whether or not you want us to keep track of your actions with us.
  • Every two years, we will renew our request to maintain your contact data on file. Such requests are limited to the right by Credit Spread Trading to send you email as outlined in (1) and or (2) above. You may choose not to renew this request or to remove this request at any time; if we do not have a legitimate consent on file, your data will be deleted from our system and we will not contact you via email.
  • Data collected for purposes of purchases of products or services will be maintained in accordance with tax laws of the United States of America and the State of Massachusetts.
  • Such data will be maintained for a period not less than seven years
    for purposes of compliance with Internal Revenue Service and State of Massachusetts Comptroller requirements.

Please note that we may ask you to verify your identity before responding to such requests.

You may file complaints with your local Data Protection Authority about our collection and use of your Personal Data.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), to provide the Service on our behalf, to perform Service-related services or to assist us in analyzing how our Service is used.

These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose and must conform to Global or Country-specific laws, where necessary and applicable.

Visitor, Email and Website Analytics

We may use third-party service providers to monitor and analyze the use of our websites, products, services, email, video, webinars and other engagement tools as produced in conjunction with Credit Spread Trading’s legitimate business purpose.

Third party service providers must meet all local, state, country or other legal requirements prior to becoming a service provider with Credit Spread Trading.

Third-party service providers must adhere to EU-GDPR and disclose what personal information, if any, is collected, used or distributed. Credit Spread Trading’s third-party service providers do not disclose personal information collected outside of the sole purpose and intent of providing Credit Spread Trading’s Products and services to its customers and visitors.

Advertising and Remarketing

Credit Spread Trading, LLC may elect to use remarketing services by Google, Yahoo, Bing, Facebook or other platforms to advertise on third party websites to you after you visited our website or after you have followed an advertisement of ours. Please be aware that cookies are used by Credit Spread Trading and its third-party services to inform, optimize and serve ads to you based on your past visits to our website, advertisement, content, video, webinar, product or service.

Google AdWords: Google AdWords is provided by Google Inc.

Google provides you with a choice to remove yourself and prevent data from being collected. Please visit the Google Privacy & Terms web page:
https://policies.google.com/privacy?hl=en

Yahoo, Bing and Facebook:

All other third-party advertising services are governed by the Privacy Policy of each service individually.

Links to Other Sites

Our websites may contain advertisement links to other sites that are not operated by us, as delivered by Google AdSense or other third-party advertising platforms.  If you choose to select an advertisement of a third-party, you will be directed to that third party’s site. We advise you to review the Privacy Policy of any site you visit.

We do not control nor do we assume any responsibility for the content, privacy policies or practices of any third-party sites or services which you may visit, without respect to the origination of the visit.

Children Privacy Statement

Credit Spread Trading LLC’s products, services, websites, content, videos or any other information accessible by the Internet is not intended for anyone under the age of 18 (“Children”).

If you are under the age of 18, this website and its products and services are not for you. We make no attempt to collect personal data or information from individuals under the age of 18. Any Personal Data collected from children without verification of parental consent, will be removed from our servers.

Parental Control: If you become aware that your child has provided personal information to Credit Spread Trading, please contact us for removal of that information.

Your California Privacy Rights

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our customers who are California residents to request and obtain from us once a year, free of charge, information about the personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year.

Credit Spread Trading LLC does not share personal information in any form, kind or format with third parties for the purposes of direct marketing by such parties. Any and all communications pertaining to a third-party are delivered to you via email by Credit Spread Trading which carry such warnings as “This is an advertisement by a partner of Credit Spread Trading,” or by advertisement on a website owned by Credit Spread Trading as served by Google Ads.

Any such advertisements do not transmit or transfer your personal data to such third parties unless you, yourself, provide such information to said parties through hyperlinks or other data collection practices.

Changes to This Privacy Policy

We may update our Privacy Policy. We will notify you of any changes by placing the new Privacy Policy on this page.

Changes to Credit Spread Trading’s Privacy Policy are effective when they are posted on this page.

Contact for any purposes related to this Privacy Policy: info@creditspreadtrading.com or by mail at:

Credit Spread Trading, LLC
3 Forest Lane
Norfolk, MA 02056
RE: Privacy complaint or compliance assistance