Privacy Policy 

I. Introduction  

Bull or Bear Ltda (“Company”, “we”, “us”, or “our”) wants to provide the best experience and resource on our website (“Site”) to our customers (“you”, “your”, “User”, or “Member”) throughout our Site, comment-enabled forums, and other services (“Services”). We respect our Users and want to remain transparent and respectful of each person’s privacy, so we have created this Privacy Policy to explain how and why we collect, share, and use particular information and how we will protect your personal privacy within our Site. 

You can access the Site without revealing your identity or any information about yourself. There are times, however, when we may need your personally identifiable information (“Personal Information”). We have tailored our Site to give Users as much control as possible over their Personal Information. If and when Personal Information is required, we agree to protect the privacy of that information in compliance with the Personal Information Protection and Electronic Documents Act, which requires every organization to obtain the consent of individuals before collecting, using, or disclosing personal information in the course of commercial activity. Additionally, Bull or Bear Ltda will take numerous precautions—including administrative, technical, and physical measures—to ensure the most complete protection of your Personal Information against loss, theft, misuse, unauthorized access, disclosure, alteration, and/or destruction.

Additionally, we will not publish any Personal Information on this Site without your consent. Any and all information collected at this Site will be kept strictly confidential and will not be sold, reused, rented, leased, loaned, traded, or otherwise disclosed to a third party. In accordance with this Privacy Policy, your Personal Information may be shared with legal entities within Bull or Bear Ltda or third-party companies with whom we have strategic relationships with to provide better service on your behalf. 

We request that you read this Privacy Policy carefully. By using our Site and Services, you are agreeing to the terms of this Privacy Policy and the accompanying Terms of Service, which govern your use of our Site and Services. 

This Privacy Policy sets out the relationship between Users Bull or Bear Ltda in relation to Personal Information shared, and it applies to the use of our Site and Services. Our Services may change from time to time, which may change the way we collect or process your Personal Information. We will update this Privacy Policy to reflect these changes. Unless otherwise stated or updated, our Site and Services will be subject to this Privacy Policy.

II. What Information is Collected and How We Use That Information  

When Users purchase or register for our Content and/or Services on our Site, we or third-parties who provide services to us collect, store, and use Personal Information including, but not limited to, name, physical and/or electronic mail address, telephone, details of transaction history, and other similar information. We do not request or store sensitive information from our non-User visitors, such as credit card information or other Personal Information. 

Bull or Bear Futures identifies the purpose for which such Personal Information is collected. If the purpose is not listed below, the purpose shall be stated before or while the information is being collected. You will be deemed to consent to our use of your Personal Information for the purpose of:

1. communicating with you generally 

2. processing your User account and access to our Site, Content, and Services;

3. processing and keeping track of transactions; 

4. identifying Users on our comment-enabled forums; 

5. protecting against fraud or error;

6. recommending products, services, and events that Bull or Bear Ltda believes would be of interest and provide value

7. performing statistical analyses to better improve the Site’s design and navigation;

8. personalizing online advertisements that Bull or Bear Ltda believes will be of interest and provide value;

9. fulfilling any other purpose that would be reasonably apparent to the average person at the time of collection; and

10. complying with legal and governmental requirements. 

III. Internet Protocol Address

We collect an IP address from all visitors to our Site. An IP address is a number that is automatically assigned to your computer when you use the Internet. We use IP addresses to help diagnose problems with our server, administer our Site, analyze trends, track User movement, gather broad demographic information for aggregate use to improve the Site, and deliver customized personalized content. IP addresses are not linked to personally identifiable information and are analyzed anonymously. 

IV. Cookies

Our Site may use cookies to enhance User experience while using our Site. Cookies are pieces of information that some Sites transfer to computers while browsing, and they are used for record-keeping purposes. Use of cookies make web-surfing easier by performing functions such as saving your passwords and your preferences for each website. The use of cookies is considered to be an industry standard, so your browser default is likely set to accept cookies. Any changes to such may affect the availability and functionality of our Site, Content, and Services. 

V. E-Mail Lists and CAN-SPAM Compliance

Users who register and/or purchase our Content and Services on the Site will be added to a marketing newsletter. We maintain e-mail lists to inform you about Bull or Bear Futures, our activities, promotions, and updates. We do not and will not sell, reuse, rent, lease, trade, or otherwise divulge the e-mail addresses on our lists to any third parties. 

Bull or Bear Ltda will use commercially reasonable efforts to ensure that our subscribed e-mail lists will not be used for chain letters, junk mail, spamming or any use of distribution lists to any person who has not given specific permission to be included in such a process. In addition to the “unsubscribe” option within the e-mail, you may contact us at thiago@bullorbearfutures.com to unsubscribe from our e-mails. 

Without limiting the foregoing, Bull or Bear Ltda may use internal site features or e-mails to provide notice of things such as updates, price changes, or other news. You also agree that we may communicate with you through any available means including email, any provided phone number, or physical mail to locations associated with your account with the Site. 

VI. Access to Personal Information

Bull or Bear Ltda will, at the request of a User, provide that User with access to all Personal Information tied to that specific User account. The company requests that the User provides and maintains accurate information by requesting appropriate corrections, deletions and/or additions to ensure that the information is accurate, relevant, up-to-date, and complete. At the request of the User, we will delete all information related to that specific User. If you have any concerns about your Personal Information or about our privacy practices, you may contact us at thiago@bullorbearfutures.com. 

VII. Comment-Enabled Forums

We may operate comment-enabled forums both on our Site and on third-party software (“Forum”). Any information you disclose in our Forums becomes public information to our other Users. Please exercise caution regarding any information you post, whether personally identifiable or not. Any information you disclose or post on our Forums may remain publicly available. Bull or Bear Ltda will never disclose any Personal Information of any of our Users on our Forums. 

VII. Security

All information provided to Bull or Bear Ltda is transmitted using SSL (Secure Socket Layer) encryption. SSL is a proven coding system that lets your browser automatically encrypt or scramble data before you send it to us.

For Users, your passwords protect your User account, so it is recommended that you use a unique and strong password, restrict access to your computer and browser, and log out of your account when done. Do not share your password or your account with anyone else. 

We take commercially reasonable steps to protect User Personal Information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. Please understand, however, that no security system is impenetrable. We cannot ensure nor warrant the security of our databases or the databases of the third parties with which we may share such information, nor can we guarantee that information you supply will not be intercepted while being transmitted over the Internet. In the unlikely event of a data breach, we will notify local data protection authorities within seventy-two (72) hours of discovery. Unless the breach occurred from our gross negligence and/or failure to maintain security compliance, Bull or Bear Ltda shall not be held liable for any third-party security breaches. 

VIII. COPPA (Children’s Online Privacy Protection Act)

As stated in our Terms and Conditions, Bull or Bear Ltda Site, Content, and Services are not directed at children under the age of 18 years. We do not and will not knowingly collect Personal Information from children under 13 years or any person under the applicable age limit (“Restricted Minor”). If you are a Restricted Minor, do not utilize Bull or Bear Ltda Site, Content, and Services, and do not provide any Personal Information to us. 

If we discover on our own that a User is a Restricted Minor and Personal Information has been collected, we will take reasonable steps to delete the data, including, but not limited to, deleting and restricting access to our Site, Content, and Services. 

VIII. General Data Protection Regulation 

The General Data Protection Regulation (GDPR) imposes additional requirements for companies that collect or store personal data of European residents. Bull or Bear Ltda complies with the applicable data protection regulations the GDPR imposes. We have established a number of measures to ensure that Users and their data are treated consistent with GDPR privacy principles including:

1. Obtaining consent before collecting, using, and storing Personal Information;

2. Informing Users of why we are processing their data;

3. Allowing Users the right to withdraw consent and disposing of all relevant information within a reasonable timeframe;

4. assessing our data processing activities to improve our protection;

5. Ensuring that when and if we work with third-parties, we have a data processing agreement with them;

6. Notifying local data protection authorities of data breaches within 72 hours of discovery; and

7. Complying with any other required EU regulations on the transfer of Personal Information. 

IX. Changes to Privacy Policy 

We may change this Privacy Policy from time to time to reflect changes in how we handle your privacy. If the changes result in less protection for your Personal Information than those provided previously, we will make reasonable efforts to contact you to let you know. By accessing the Site, Content, and/or Services after we make any such changes to this Privacy Policy, you are deemed to have agreed to be bound by such changes. The most current version of this Privacy Policy can be reviewed by visiting the Site and clicking on “Privacy Policy” at the bottom of the home page. The most current version of the Privacy Policy will supersede all previous versions.  

X. Contact Us 

All questions regarding this Privacy Policy should be directed to Bull or Bear Ltda by sending an e-mail to thiago@bullorbearfutures.com. Please reference this Privacy Policy in your subject line.