BullsPub is committed to protecting your privacy. We developed this Privacy Policy to share with you our information collection practices and the options you have when visiting http://bullspub.com or using its applications or related services (hereinafter referred to as “the Website” or “the Site”) via any client or application. This Privacy Policy is an online Privacy Policy and applies only to information collected from you through this Website. This Privacy Policy does not apply to information that you furnish to us offline or in any other manner except through this Website.

By using this Site, you are agreeing to accept the practices described in this Privacy Policy. BullsPub occasionally may update this Privacy Policy. When we do, we will revise the "updated" date at the top of the Privacy Policy. In the event that we make material changes to this Privacy Policy, we will notify you at our option either by placing a prominent notice on the home page of our Website or by sending you a notification directly. We encourage you to review this Privacy Policy periodically to stay fully informed about how we are protecting your personal information. Be advised that your continued use of this Website constitutes your agreement to this Privacy Policy and any updates.

As referenced throughout this Privacy Policy, the term “Personally Identifiable Information” means any piece of information that potentially can be used to uniquely identify, contact, or locate a single person and that BullsPub collects from you. Personally Identifiable Information includes, without limitation, the following: user name, password, first name, last name, address, e-mail address, phone number, birth date, credit card number, IP addresses, audio or video in which you are depicted or identifiable, etc.

Any Personally Identifiable Information collected by BullsPub will be safeguarded to protect against unauthorized access. Procedures are in place to secure any personal information provided to BullsPub. BullsPub stores your personal information in a computer database on dedicated servers that allow only limited access. BullsPub employs commercially reasonable efforts to protect this information from loss, misuse, and other unauthorized disclosure, alteration or destruction.

BullsPub and its affiliates are the sole owners of the information collected; except as otherwise provided in this Privacy Policy, we will not sell, share or loan this information to any third party. However, we may use and share aggregated information that does not personally identify you with third parties in order to improve the Site for our Website users. You can always be assured the information we collect is used to provide a more personalized experience for our Website users. Such "site usage" and statistical information may be made public information at BullsPub’s discretion.

Please note that we do not control all content served in conjunction with our Site. BullsPub site may include content from other parties that may perform user activity tracking other than that described herein. In particular, some of our partners may use "cookies" in ways that we do not. None of the required information and/or optional information collected on any form on this Website is used for other purposes than those stated on such form or in this Privacy Policy; however, as discussed below in more detail, BullsPub may share information provided through the Website with third parties under contract with BullsPub to assist in providing certain services or other features offered to our Website users. In the event that BullsPub utilizes a third party to provide such services, our contract with the third party will include obligations upon the third party to keep all information obtained during such contract confidential and secure.

Although you may browse the public pages of our Website without registering or providing any Personally Identifiable Information other than IP addresses, certain sections of our Site do include forms on which you may choose to supply personalized information that will enable you to make purchases online, access premium content or receive individualized services or features that we cannot offer anonymous users, and certain other pages of our Website can be accessed only by registered users. You can always choose not to provide information; however, if you do choose not to provide such information, you may not be able to make purchases via the Site, access certain areas of the Website, obtain premium content, or take advantage of certain other Website features.

Except as necessary to facilitate or fulfill any aspect of any services, products or features that you purchase, request, register for or subscribe to via the Website, or as otherwise set forth in this Privacy Policy, we will not intentionally sell, lease, share or exchange your Personally Identifiable Information with any third party.

In order to access pages requiring registration, you will be required to create a User Account by completing the registration form and creating a User ID, alias and password. If you create a User Account, BullsPub collects certain Personally Identifiable Information when you register, including your user name, alias, password, first name, last name, and e-mail address.

In response to concerns about protecting children's privacy online, Congress enacted the Children's Online Privacy Protection Act of 1998 ("COPPA"), which sets forth rules and procedures governing the ways in which Web sites may collect, use and disclose any personal information for children under the age of 13. BullsPub does not target children under the age of 13 and does not offer or knowingly sell any of its products or services to children. Moreover, BullsPub DOES NOT:

1. Request or knowingly collect personally identifiable online or offline contact information from users under 13 years of age;

2. Knowingly use or share personal information from users under 13 years of age with third parties;

3. Give children the ability to publicly post or otherwise distribute personally identifiable contact information;

4. Entice children with the prospect of a special game, prize or other activity to divulge more information than is needed to participate in the activity.

The following are categories of pages on the Website where we collect Personally Identifiable Information about you.

Alerts & Notices

Our Website offers features that allow you to receive electronic alerts, such as Free Stock Picks, Daily Markets Bulletin, Forex Weekly News, BullsPub Service Announcements, Commercial and Special Offers List, notices about updates to our Website, other promotional announcements, new products and other information. When you sign up for such electronic alerts or notices, we will collect certain Personally Identifiable Information, which may include without limitation your name, mobile number (if you opt in to receive text alerts), e-mail address and other basic contact information. As noted, we will send you occasional updates about the site, various market update information from us and our parent company, ADVFN, and select advertising via email. In any such email you will have an "opt-out" link you can use to remove yourself from the lists for any and all specific types of emails we may send. We send the emails ourselves and do NOT give or sell your email address to marketers or anyone else.

Various pages on our Website include forms that permit you to subscribe to newsletters or other subscriptions. When you register to receive newsletters or other subscriptions, we will collect certain Personally Identifiable Information, which may include without limitation your name, address, phone number, e-mail address, confirmation of age and other basic contact information.

In addition to the above information, certain forms on various pages throughout our Site may ask users to voluntarily provide a limited amount of demographic information. In addition, BullsPub or its affiliates may conduct online surveys that ask you for demographic data, such as your zip code, age or income level. BullsPub or BullsPub's agents may also contact you by e-mail, using your e-mail address collected when you filled out one of the forms on our Website, with the option to participate in consumer research studies. Providing such demographic information and participating in such surveys or other consumer research are always voluntary. BullsPub aggregates the responses we receive before using the information to improve the products and services we offer. We do not link your individual responses to your personal information at any time. BullsPub uses this information only for internal marketing research to help us better serve our users and customers.

From time to time, BullsPub may offer sweepstakes, contests or other games. If you participate in such promotions, BullsPub may ask for some personal information, such as names, phone numbers, e-mail addresses, or other contact information, so that we can contact potential contest or sweepstakes winners. We will clearly post the rules and terms of each contest or sweepstakes. Please note that, from time to time, BullsPub may retain third party vendors to administer such sweepstakes, games or contests and in such circumstances, those third parties will be required to collect your personal information in order to administer and fulfill the promotion, as well as to contact potential winners. Please review the Official Rules for such promotions carefully, as the personal information collected during these promotions may be subject to the privacy policies of these third party vendors as well as this Privacy Policy. In that event, the Official Rules will refer you to the privacy policy of the third party vendors. Please review those privacy policies as well, because BullsPub does not have control over the treatment of personal information by such third party vendors.

As noted above, if you have opted in to receive marketing, promotional or other informational communications from or on behalf of BullsPub, we may use your e-mail address from time to time to contact you to announce new features, products or services that may be available in our stores or on our Website or to send news and information regarding BullsPub or its products or services. You can opt out of receiving these promotional communications at any time by following the instructions in the e-mail.

We may also use your e-mail address to contact you to verify and/or update any information related to services, features or transactions that you have requested via our Website. Although you may opt out of the promotional e-mails as noted above, you should be aware that, that as long as you use our products and services or otherwise maintain a business relationship with us, however, you may not opt out of receiving communications from us relating specifically to those products and services or that business relationship.

You may also provide Personally Identifiable Information to us when you voluntarily communicate with us, such as by requesting information via e-mail, utilizing the private message features on the Website, or otherwise contacting us electronically. We may retain such Personally Identifiable Information for use and disclosure consistent with this

Change in Ownership or Business Transfers 

As we continue to develop our business, we might sell or buy assets. In such transactions, customer information generally is one of the transferred business assets. Also, in the event that BullsPub or substantially all of its assets are acquired, customer information, including Personally Identifiable Information, will of course be one of the transferred assets to the extent permissible under law.

We collect additional information about how you use and access our Website to analyze trends, administer our Website, track user’s navigation on the Site and gather broad demographic information for aggregate use, which enables us to improve the Site by making it more accessible and easier to navigate. For example, we may automatically receive and record information in our server logs from your browser, including your IP address (the Internet address of your PC), your computer’s name, the type and version of your web browser, referrer addresses and other generally-accepted log information. IP addresses may be linked to other Personally Identifiable Information. We may also record page views (hit counts) and other general statistical and tracking information, which will be aggregated with that of other users in order to understand how our Website is being used.

 

By use of this Website, you consent to our use of cookies. A "cookie" is a piece of data stored on your hard drive containing information about you. Cookies do not contain any registration information that would personally identify you, as all such data is kept behind our firewall. Cookies do not allow us to track your usage of other Websites or the Internet in general. In addition, when registered users visit our Website and log-in using their passwords, our Website uses "persistent cookies" and/or "session cookies." Cookies are a form of technology that a server exchanges with your browser when you access our Website or a section of the Website, Cookies allow you to navigate our Website without being required to enter your password more than once during your visit to our Website. When logging in to the Website, checking the "Remember me" box will result in a persistent cookie; unchecking it will result in a session cookie being used instead. Most web browsers are set to accept cookies by default, though you can manually disable the cookies feature of your browser. You should review the online documentation relating to your browser or consult with the provider of your browser for instructions on how to disable cookies. Please note that if you disable cookies on your computer, some parts of the Website may not function properly or offer you the same degree of personalization. Some generalized information about cookie technology can be found at allaboutcookies.org.

A “referrer” is the information passed along by a web browser that references the web URL you linked from and is automatically collected by our Web server. We may collect and use this information to understand the Websites referring traffic to our Website and to present appropriate content to our potential users. We may tabulate referrer information on an aggregate basis to identify trends and traffic patterns. BullsPub may share aggregated demographic information with our partners. This is not linked to any personal information that identifies any individual person. BullsPub may use your profile information to create personalized content, offers, and services, but this information will only be used by BullsPub and its affiliates.

BullsPub and its affiliates may disclose any or all of your Personally Identifiable Information if we are required to do so by law or in the good faith belief that such action is necessary to: (a) conform to the law or comply with legal process served on us (for example, under a subpoena, court order or other regulatory requirement or to maintain or protect the security of the Website); (b) protect and/or defend our rights or property or other legal interests or of any Website user; or (c) act in urgent circumstances to protect the safety of the public or other users of the Website. This includes exchanging information with other companies and organizations for fraud protection and credit risk reduction.

From time to time we receive requests to disclose the identities of our users. As noted above, we do not disclose the identities of our users unless we are legally required to do so. However, you should be aware that the identifying information specific to your use of BullsPub, including your IP address, name, and email address will be delivered when requested by a legal subpoena, subject to the following: If a governmental agency (for example, the Securities and Exchange Commission, law enforcement agencies, United States Attorneys' offices or similar governmental agencies) sends us a subpoena, we will comply with it. If we receive a subpoena by a third party that is not a governmental agency (for example, a subpoena in connection with civil litigation), we will attempt to contact the user whose identity has been requested using the contact information the user provided during the registration process including by email and/or a message sent to your BullsPub account so that you may seek to prevent our delivery of this information or quash the subpoena. We will wait 10 days after notifying the user before complying with the subpoena by disclosing the identity of the user, unless the subpoena requires us to disclose this information before then. If we cannot wait 10 days because of the deadline in the subpoena, we will advise the user of the deadline included in the subpoena when we provide notice that we received it. If you are a paying subscriber to BullsPub, you are able to send and receive private messages using our database system. Our policy is that we will not deliver the contents of private messages to anyone, even when demanded via subpoena. As a user of BullsPub, however, you should understand that this is no guarantee that we won't someday be forced by a court to deliver this information. It hasn't happened yet, but please be advised that it is possible.

We use third-party advertising companies to serve ads when you visit our website. These companies may use information (not including your name, address, email address, or telephone number) about your visits to this and other websites in order to provide advertisements about goods and services of interest to you. In addition, in the course of serving advertisements to this site, our third-party advertisers may place or recognize a unique “cookie” on your browser.

You should be aware that there is an inherent risk in transmitting any data electronically. This risk is inherent in all Internet dealings. Consequently, we cannot guarantee that any Personally Identifiable Information transmitted will be prevented from being viewed or used by any particular person and therefore, you agree to hold us harmless from and against any injury, financial or otherwise, that results from such unauthorized viewing or use. Moreover, e-mails sent to us over the Internet are susceptible to detection, decryption, eavesdropping or tampering. Thus, you agree to hold us harmless from and against any harm, financial or otherwise, that results from such detection, decryption, eavesdropping or tampering of e-mails. In addition, you must take steps to maintain the security of your private information by keeping your password and other personal information confidential. It is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.

Our Site may contain links to other sites. Please be aware that BullsPub is not responsible for the privacy policies of other sites. We encourage our Website users to be aware when they leave our Website and to read the privacy statements of each and every Website that collects Personally Identifiable Information. This Privacy Policy applies solely to the information collected by our Website.