Global OTC

Privacy Policy

Global OTC is committed to protecting the privacy of users of our services, including our online website (the “Site”). This Privacy Policy describes our practices concerning the personally identifiable information that we collect, such as your name, email address, telephone number, postal address, or company and job title (“personal information”). This Policy also describes our privacy practices with respect to other information that we collect through our Site, such as your IP address and how you use the Site.

The personal and other information that we collect about you is controlled by Global OTC, which is headquartered in the United States at 353 N. Clark Suite 3200 Chicago, IL 60606. By using the Site or our other services, you agree with and consent to the terms of this Policy.

WHAT PERSONAL AND OTHER INFORMATION WE COLLECT ABOUT YOU

Personal information. We may collect certain personal information about you. This information could include, for example, your name, email address, telephone number, postal address, and/or company and job title. It also may include other information that we associate with your personal information, such as customer service records or information about our communications with you. We collect this information through a variety of means, including our registration application and other forms, your communications and dealings with us (e.g., emails and telephone calls), and other contexts where your information is shared with us. Importantly, however, we do not collect any information through the Site that we can use to identify you personally. Instead, as discussed below, the Site collects more limited information through certain online tracking mechanisms.

Web log data. When you use the Site, we automatically receive and record certain information from your computer (or other device) and your browser. This may include such data as your IP address and domain name, the pages you visit on the Site, the date and time of your visit, the files that you download, a referring URL from the website you visited before navigating to the Site, your software and hardware attributes, your general geographic location (e.g., your city, state, or metropolitan region), and certain cookie information (see below). To obtain such information, we may use web logs or applications that recognize your computer and gather information about its online activity. We also may partner with certain third parties to collect and analyze some of this information (see the section below entitled “How we share personal and other information with third parties”).

Cookies. We also use cookies on the Site. Cookies are small files that are stored on your computer by your web browser. A cookie allows the Site to recognize whether you have visited before and may store user preferences and other information. For example, cookies can be used to collect information about your use of the Site during your current session and over time (including the pages you view and the files you download), your computer’s operating system and browser type, your Internet service provider, your domain name and IP address, your general geographic location, the website that you visited before the Site, and the link you used to leave the Site. If you are concerned about having cookies on your computer, you can set your browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your computer. However, if you choose to block or delete cookies, certain features of the Site may not operate correctly.

HOW WE USE THE PERSONAL AND OTHER INFORMATION THAT WE COLLECT

Global OTC uses the information that we collect for a variety of purposes. If we have personal information about you, we may use it, for example: to evaluate your eligibility to use certain services that require registration; to respond to your questions or requests concerning the Site or other services offered by Global OTC or our partners; to fulfill the terms of any agreement you have with us; to fulfill your requests for our services or otherwise complete a transaction that you initiate; to send you information about our services and other topics that are likely to be of interest to you, including newsletters, updates, or other communications; to deliver confirmations, account information, notifications, and similar operational communications; to improve your user experience and the quality of our products and services; to comply with legal and/or regulatory requirements; and to manage our business.

We use the other information that we collect for such purposes as: authenticating you when you use certain Global OTC services that require registration; counting and recognizing visitors to the Site; analyzing how visitors use the Site and various Site features; improving the Site and enhancing users’ experiences with the Site; creating new products and services or improving our existing products and services; enabling additional website analytics and research concerning the Site; and managing our business.

We also may use the personal and other information that we collect to send you promotional communications, including emails or postal mail about the products and services offered by Global OTC or our partners. Although we hope you will find our promotional emails of interest, you may opt out of receiving them by sending an email to info@globalotc.com with “optout” in the subject line. Promotional emails will also have instructions for opting out of that type of communication in the future.

HOW WE SHARE PERSONAL AND OTHER INFORMATION WITH THIRD PARTIES

We partner with certain third parties to collect and analyze the information discussed above. These third parties may use web logs or set and access cookies on your computer or other device. The use of online tracking mechanisms by third parties is subject to their own privacy policies, and not this Privacy Policy. If you would like to prevent third parties from setting and accessing cookies, you may set your browser to block cookies. In particular, the Site uses Google Analytics to help collect and analyze certain information for the purposes discussed above. You may opt out of the use of cookies by Google Analytics here.

We also use other third-party service providers to help us manage and improve the Site and other Global OTC services. These service providers may collect and/or use your personal or other information to assist us in achieving the purposes discussed above. For example, we use third parties to help us target and implement our email communications and direct mailings. We also use third-party platforms to help us manage our relationships with the people and companies that use our services.

We may share your personal or other information with other third parties when necessary to fulfill your requests for services; to complete a transaction that you initiate; to meet the terms of any agreement that you have with us or our partners; or to manage our business. For example, we may share your information with issuers of securities that you purchase or with other entities as necessary to complete a trade.

Finally, we also may use or share your information with third parties when we believe doing so is necessary:

To comply with applicable law or a court order, subpoena, or other legal process;

To investigate, prevent, or take action regarding illegal activities, suspected fraud, violations of our terms and conditions, or situations involving threats to our property or the physical safety of any person;

To establish, protect, or exercise our legal rights or defend against legal claims; or

To facilitate the financing, securitization, insuring, sale, assignment, or other disposal of all or part of our business or assets.

SECURITY

We use commercially reasonable physical, electronic, and procedural safeguards to protect your personal information against loss or unauthorized access, use, modification, or deletion.

Reviewing and updating your information

If you want to learn more about the personal information that Global OTC has about you, or you would like to update or change that information, please contact us by email at info@globalotc.com.

INFORMATION FOR SITE USERS FROM OUTSIDE THE UNITED STATES

The personal and other information that we collect through the Site or in connection with our other services is transferred to and processed in the United States for the purposes described above. Global OTC also may subcontract the processing of your data to, or otherwise share your data with, affiliates or third parties in the United States or countries other than your country of residence. The data-protection laws in these countries may be different from, and less stringent than, those in your country of residence. By using the Site or our other services, you expressly consent to such transfer and processing.

CHANGES TO THIS POLICY

Global OTC may update this Privacy Policy from time to time. We will post all such changes on the Site, so you should review this Privacy Policy periodically. If we make a material change to the Policy, you will be provided with appropriate notice.

Effective date: September 12, 2013