Effective May 21, 2024

Your privacy is very important to us. We value the relationships we build with our customers, and we feel that keeping your information confidential is crucial to the customer service we provide. You do not need to instruct us to keep your information confidential; we do this for you automatically. We have established this privacy policy (“Privacy Policy”) to explain to you how your personal information is protected, collected, and used when you use this ITM Trading Inc. website (the “Site”) or our services accessible through the Site (the “Services”). Personal information is information about you that is personally identifiable, such as your name, email address, and other information, that is not otherwise publicly available (“Personal Information”).

This notice applies to the information collected or submitted on the Site. Please read this Privacy Policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Site. By accessing or using this Site or using our Services, you agree to be bound by the terms and conditions of this Privacy Policy. This Privacy Policy may change from time to time. Your continued use of this Site and the Services after we make changes is deemed to be acceptance of those changes, so please check the Privacy Policy periodically for updates. We reserve the right to modify this Privacy Policy at any time, so please review it frequently.

The Information We Collect and Use:

To access the Site or use the Services, you may be required to create a user account, including user ID and password, and input certain Personal Information, including your email address. We collect Personal Information from you to allow us to provide the Services that will most likely meet your needs and preferences.

This includes payment information: When you make a payment, we collect and store the amount, and either your credit card number and expiration date, or your bank information.

In general, you can browse the Site and “opt-out” from providing us with any Personal Information. Once you agree to provide us with Personal Information, you are no longer anonymous to us. On some pages you can make requests and register to receive materials. If you choose to use and/or purchase certain Services we may require you to provide contact and identity information, billing information, and other Personal Information as indicated on the forms throughout the Site. Where possible, we indicate which fields are required and which are optional. You always have the option to not provide information by choosing not to use or purchase a particular service.

The types of Personal Information collected at these pages may include:

Name

Address

Email address

Phone number

Fax number

Payment Information

We also collect information from and about users of our Site. We collect this information automatically as you navigate the Site. Information collected automatically may include information usage details, IP addresses, and information collected through cookies.

The Way We Use Information:

We use the information you provide about yourself when requesting information to provide the Services, customize your experience on our Site, complete orders, enforce our policies, resolve disputes, and troubleshoot problems. We may compare and review your Personal Information for errors, omissions, and accuracy.

You agree that we may use your Personal Information, including your email address, to improve our marketing and promotional efforts, to analyze Site usage, to improve the Services, and to customize the Site’s content, layout, and services. These uses improve our Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe, and customized experience while using the Site and/or the Services.

Due to the existing regulatory environment, we cannot ensure that all of your private communications and other Personal Information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), we may be forced to disclose Personal Information, including your email address, to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or users may abuse or misuse your Personal Information that they collect from Company. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should neither rely upon nor expect, that your Personal Information or private communications will always remain private.

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.

Communications

The email address you provide for order processing, may be used to send you information
and updates pertaining to your order, in addition to periodic company news, updates,
and/or related product or service information, etc. If you decide to opt-in to our mailing list, you will receive emails that may include company news, updates, related product or service information, promotions, etc. However, you may opt-out at any time by clicking the unsubscribe button at the bottom of your emails.

We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if access to our products is temporarily suspended for maintenance, we might send you an email or text message. Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, please do not submit your Personal Information through our Site.

Cookies

We customize certain Web page content based upon your browser type and other information provided by our cookie. If you choose to reject the cookie, you can still browse our store but will be unable to use the shopping cart to buy merchandise. The Site shopping cart cannot function without cookies enabled so that the necessary information to process your order is retained. If you disable cookies, itmtrading.com will be unable to accept your online order. We will not share any personally identifiable information provided by this cookie with any third party. We will, however, link data stored in cookies to the Personal Information you submitted while on our site. This allows us to personalize your shopping experience and discern user preferences to evoke subconscious feelings of familiarity and assurance.

Third-Party Use of Cookies and Other Tracking Technologies

We allow third-party companies to collect non-personally identifiable information when customers visit our Site. These companies typically use a cookie or web beacon to collect this information in order to provide advertisements likely to be of interest to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. Our site does not respond to “Do Not Track” signals or mechanisms.

Users in the United States may opt out of many third-party ad networks. For example, you may go to the Digital Advertising Alliance (“DAA”) Consumer Choice Page for information about opting out of interest-based advertising and your choices regarding having information used by DAA companies. You may also go to the Network Advertising Initiative’s (“NAI”) Consumer Opt-Out Page for information about opting out of interest-based advertising and your choices regarding having information used by NAI members. The NAI’s main webpage is located at www.networkadvertising.org.

Opting out from one or more companies listed on the DAA Consumer Choice Page or the NAI Consumer Opt-Out Page will opt you out from those companies’ delivery of interest-based content or ads to you, but it does not mean you will no longer receive any advertising through our Site or on other websites or applications. You may continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you opt out on the DAA or NAI websites, your opt out may not be effective. Additional information is available on the DAA’s website at www.aboutads.info or the NAI’s website.

We do not control these third parties’ tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Credit Card Information

Under some circumstances we may require some additional financial information. We use your financial information, including credit card information, to verify the accuracy of your name, address and other information, as well as to bill you for your use of our services and products.

For your safety and protection, your credit card information is not stored on
our servers. Our payment gateway provider, Authorize.net, keeps this information encrypted and secure on your behalf.

How You Can Access or Control Your Information

You can access all your Personal Information that we collect online and maintain by calling or emailing our corporate offices. We use this procedure to better safeguard your information. We will also take reasonable steps to verify your identity before granting access or making corrections.

Any personal data that we collect is based upon your consent as detailed in this Privacy Policy. You have many choices concerning the collection, use, and sharing of your data, including the ability to:

• Delete Data: You may request that we delete your Personal Information. Please note that we cannot delete your Personal Information except by also deleting your user account.
• Change or Correct Data: You can also ask us to change, update, or fix your data in certain cases, particularly if it’s inaccurate.
• Object to, or Limit or Restrict, Use of Data: You may request that we do not use your Personal Information, but keep in mind that this will terminate our ability to provide any Service(s) to you.
• Right to Access and/or Take Your Data: You can ask us for a copy of your Personal Information.

You may send us an email at services@itmtrading.com to request access to, obtain copies of, correct, or delete any Personal Information that you have provided to us. We may not accommodate a request to change or delete information if we believe the change or deletion would violate any law or legal requirement or cause the information to be incorrect.

Your California Privacy Rights

California Civil Code Section § 1798.83 permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to services@itmtrading.com

Children Under the Age of 18 

We do not collect any Personal Information from children under the age of 18. If you believe that a child has provided us with Personal Information without the consent of his or her parent or guardian, please contact us at services@itmtrading.com. If we become aware that a child under age 18 has provided us with Personal Information, we will delete it.

Security

We follow generally accepted industry standards to protect Personal Information, including your email address, submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, we cannot guarantee its absolute security. Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Site.

The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site, you are responsible for keeping this password confidential. We ask you not to share your password with anyone.

The Telephone Consumer Protection Act:

Regulatory Summary

The federal Telephone Consumer Protection Act (“TCPA”) and related FCC regulations shield consumers from unwanted telemarketing. The TCPA regulates the sending of commercial messages via telephone, text messages, and fax. Specifically, the TCPA makes it unlawful for any person to place a call or text using an automatic telephone dialing system or an artificial or prerecorded voice without the called party’s prior express consent, except for emergency purposes.

1. Under the TCPA, covered entities may place calls (or texts) to individuals only with the prior express consent of the called party, which will be required through our website forms. For non-commercial, informational texts, that consent may be oral. For commercial texts, consent must be in writing. A consenting party may revoke his or her consent at any time and through any reasonable means, and a sender may not limit the manner in which revocation may occur.

National Do Not Call Registry. The TCPA rules provide for the National Do Not Call Registry (Registry), a joint effort launched by the FCC and the Federal Trade Commission (FTC) in 2003. Consumers can register landline or mobile phone numbers with the Registry to limit telemarketing calls that may be made to them. Sense Technology Inc. maintains its own Do Not Call List. We are required to access the registry prior to making any unsolicited telephone calls and to update our internal call lists every 31 days to reflect changes in the Registry.

General Statement of Policy

National Do Not Call Registry. The TCPA rules provide for the National Do Not Call Registry (Registry), a joint effort launched by the FCC and the Federal Trade Commission (FTC) in 2003. Consumers can register landline or mobile phone numbers with the Registry to limit telemarketing calls that may be made to them. Sense technology Inc. maintains its own Do Not Call List. We are required to access the registry prior to making any unsolicited telephone calls and to update our internal call lists every 31 days to reflect changes in the Registry.

This company does not engage in telemarketing. Any employee considering telemarketing must first consult with the executive responsible for legal affairs on appropriate procedures adhering to the TCPA and applicable state laws.

Independent agencies conducting telemarketing in specific reference to a product or marketing initiative of this company or any subsidiary shall fully adhere to the TCPA and applicable state laws.

There are strict penalties for noncompliance with the TCPA, the Pennsylvania Telemarketing Act and similar state laws. Violations may subject an agent or employee to such penalties, as well as contract termination, employment termination and other discipline.

The TCPA mandates that telemarketer:

Maintain a Do Not Call Policy

Promptly provide a copy of the Policy to requesting consumers

Only make calls between 8 a.m. and 9 p.m. (local time of the person being called)

•          Identify the caller name, company name and caller location
•          Maintain and comply with a company “do not call” list derived from the federal “do not call” registry.
•          Honor a consumer’s request made during a call to place the consumer’s name on the “do not call” list
•          Transmit caller ID information.
•          Not abandon outbound calls

No mobile information will be shared with third parties/affiliates for marketing/promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties

For More Information

To learn more about the TCPA and applicable state laws, you may visit the web site listed below.

FCC web page: https://www.fcc.gov/cgb/consumerfacts/tcpa.html

State-by-State Do Not Call List Information: https://thedma.org/resources/compliance-resources/do-not-call-lists/

How to Contact Us

Should you have other questions or concerns about these privacy policies, please
call us at 1-888-696-4653 or send us an email at services@itmtrading.com.