Privacy Policies


Privacy Policy

Effective Date: February, 2024
Effective Date: February, 2024

The following Privacy Policy governs the online information collection practices of BMF Financial Media (“we” or “us”). Specifically, it outlines the types of information that we gather about you while you are using the website (the “Site”), and the ways in which we use this information. This Privacy Policy, including our children’s privacy statement, does not apply to any information you may provide to us or that we may collect offline and/or through other means (for example, at a live event, via telephone, or through the mail).

Please read this Privacy Policy carefully. By visiting and using the Site, you agree that your use of our Site, and any dispute over privacy, is governed by this Privacy Policy. Because the Web is an evolving medium, we may need to change our Privacy Policy at some point in the future, in which case we’ll post the changes to this Privacy Policy on this website and update the Effective Date of the policy to reflect the date of the changes. By continuing to use the Site after we post any such changes, you accept the Privacy Policy as modified.
How We Collect and Use Information

We may collect and store personal or other information that you voluntarily supply to us online while using the Site (e.g., while on the Site or in responding via email to a feature provided on the Site). only contacts individuals who specifically request that we do so or in the event that they have signed up to receive our free newsletters or have purchased one of our products. collects personally identifying information from our users during online registration and online purchasing. Generally, this information includes name and e-mail address for registration to receive our free newsletters and name, postal address, and credit card information when purchasing our products. All of this information is provided to us by you.

We also collect and store information that is generated automatically as you navigate online through the Site. For example, we may collect information about your computer’s connection to the Internet, which allows us, among other things, to improve the delivery of our web pages to you and to measure traffic on the Site. We also may use a standard feature found in browser software called a “cookie” to enhance your experience with the Site. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. By showing how and when visitors use the Site, cookies help us deliver advertisements, identify how many unique users visit us, and track user trends and patterns. They also prevent you from having to re-enter your preferences on certain areas of the Site where you may have entered preference information before. The Site also may use web beacons (single-pixel graphic files also known as “transparent GIFs”) to access cookies and to count users who visit the Site or open HTML-formatted email messages.

We use the information we collect from you while you are using the Site in a variety of ways, including using the information to customize features. and advertising that appear on the Site. We also may provide your information to third parties, such as service providers and contractors for a variety of purposes. Unless you inform us in accordance with the process described below, we reserve the right to use, and to disclose to third parties, all of the information collected from and about you while you are using the Site in any way and for any purpose, such as to enable us or a third party to provide you with information about products and services. If you do not wish your information to be used for these purposes, you must send a letter to the Online Privacy Coordinator whose address is listed at the end of this Privacy Policy requesting to be taken off any lists of information that may be used for these purposes or that may be given or sold to third-parties.

Please keep in mind that whenever you voluntarily make your personal information available for viewing by third parties online – for example on message boards, web logs, through email, or in chat areas – that information can be seen, collected and used by others besides us. We cannot be responsible for any unauthorized third-party use of such information.

Some of our third-party advertisers and ad servers that place and present advertising on the Site also may collect information from you via cookies, web beacons or similar technologies. These third-party advertisers and ad servers may use the information they collect to help present their advertisements, to help measure and research the advertisements’ effectiveness, or for other purposes. The use and collection of your information by these third-party advertisers and ad servers is governed by the relevant third-party’s privacy policy and is not covered by our Privacy Policy. Indeed, the privacy policies of these third-party advertisers and ad servers may be different from ours. If you have any concerns about a third party’s use of cookies or web beacons or use of your information, you should visit that party’s website and review its privacy policy.

The Site also includes links to other websites and provides access to products and services offered by third parties, whose privacy policies we do not control. When you access another website or purchase third-party products or services through the Site, use of any information you provide is governed by the privacy policy of the operator of the site you are visiting or the provider of such products or services.

We may also make some content, products and services available through our Site through cooperative relationships with third-party providers, where the brands of our provider partner appear on the Site in connection with such content, products and/or services. We may share with our provider partner any information you provide, or that is collected, in the course of visiting any pages that are made available in cooperation with our provider partner. In some cases, the provider partner may collect information from you directly, in which cases the privacy policy of our provider partner may apply to the provider partner’s use of your information. The privacy policy of our provider partners may differ from ours. If you have any questions regarding the privacy policy of one of our provider partners, you should contact the provider partner directly for more information.

Be aware that we may occasionally release information about our visitors when release is appropriate to comply with law or to protect the rights, property or safety of users of the Site or the public.

Please also note that as our business grows, we may buy or sell various assets. In the unlikely event that we sell some or all of our assets, or one or more of our websites is acquired by another company, information about our users may be among the transferred assets.
Children’s Privacy Statement

This children’s privacy statement explains our practices with respect to the online collection and use of personal information from children under the age of thirteen, and provides important information regarding their rights under federal law with respect to such information.

This Site is not directed to children under the age of thirteen and we do NOT knowingly collect personally identifiable information from children under the age of thirteen as part of the Site. We screen users who wish to provide personal information in order to prevent users under the age of thirteen from providing such information. If we become aware that we have inadvertently received personally identifiable information from a user under the age of thirteen as part of the Site, we will delete such information from our records. If we change our practices in the future, we will obtain prior, verifiable parental consent before collecting any personally identifiable information from children under the age of thirteen as part of the Site.
Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we also do NOT knowingly distribute such information to third parties.

We do NOT knowingly allow children under the age of thirteen to publicly post or otherwise distribute personally identifiable contact information through the Site.

Because we do not collect any personally identifiable information from children under the age of thirteen as part of the Site, we do NOT condition the participation of a child under thirteen in the Site’s online activities on providing personally identifiable information.

How do we store your information?

Your information is stored at the list server that delivers content and messaging. Your information can only be accessed by those who help manage those lists in order to deliver e-mail to those who would like to receive material.

All of the messaging or emails that are sent to you by include an unsubscribe link in them. You can remove yourself at any time from our newsletters or mailing list by clicking on the unsubscribe link that can be found in every communication that we send you…


Although it is highly unlikely, This policy may be changed at any time at our discretion. If we should update this policy, we will post the updates to this page on our Website.

If you have any questions or concerns regarding our privacy policy please direct them to [email protected] .

If you have any questions or concerns regarding our privacy policy please direct them to [email protected].


Privacy Policy


This Privacy Policy is effective as of March 23, 2022.


This Privacy Policy (“Policy”) describes the practices of
MicroQuant, LLC d/b/a/ (“Base Camp Trading”, “we” or
“our”), with respect to the information provided by, or collected from,
visitors, trial members or members of this website (
) and our blogs, webinars,
videos, social media pages and all other services provided by Base Camp Trading
(collectively, the “Platform”), including information that is gathered from
correspondences (including email) from or about registrants or attendees at
events, or through interactions with Base Camp Trading’s representatives
(collectively “Services”). Such visitor(s), trial member(s), member(s),
registrant(s), and attendee(s) are each referred to herein as a “user” or “you.”


This Privacy Policy provides information as to who we are, and how
and why we collect, store, use, and share your Personal Data. It also explains
your rights in relation to your Personal Data and how to contact us or
supervisory authorities in the event you have a complaint. Base Camp Trading is
the data controller regarding all Personal Data processing conducted through
the Platform.


You acknowledge that this Privacy Policy
is part of our Terms of Use, and by accessing or using our Platform, you agree
to be bound by all of its terms and conditions. If you do not agree to these terms, please do not access or use all or any portion of the Platform.




The data controller is:                      MicroQuant, LLC

                                                                  811 Sixth Street

                                                                  Suite 220

                                                                  Wichita Falls, TX 76301


The EU Representative is:               Bourlux Limited

                                                                  1st Floor, 9 Exchange Place

                                                                  IFSC Dublin, Ireland 1


The Data Protection Officer is:      Brian Strong

                                                                  [email protected]



of Personal Data Collected and Source of the Data

Base Camp Trading collects information that a user chooses to
provide by engaging in certain activities on the Platform, for example, by
registering as a member, completing a form to download a white paper or request
a document, ordering a product or service, submitting content, exchanging email
or other correspondences with us or our representatives, and/or posting content
in discussion forums or other public areas, entering a contest or sweepstakes,
filling out a survey, or sending us feedback. We also collect information by
analyzing a user’s behavior, predispositions, preferences, activity and usage
on the Platform over time to create a profile about a user. In general, users may
visit unrestricted portions of the Platform anonymously and may refuse to
supply Personal Data, though such refusal may prevent users from accessing
portions of the Platform or participating in certain Platform related


For purposes of this Policy, “Personal Data” that we may collect and
process through the Platform or in connection with the Services means personal
information that identifies, relates to, describes, is reasonably capable of
being associated with, or could reasonably be linked, directly or indirectly,
with a particular consumer or household, including but not limited to:


Identifying Information: In various sections of the Platform (including to make a purchase
and to access designated member services and/or restricted areas) users are
asked to provide personal identifying information, such as: name, e-mail
address, phone number, billing address, account name, organization, and/or other
similar identifiers.


Payment Information: If a user requests Services (including registration to become a
trial member or member) for which payment is required, the user may be asked to
provide payment information such as: method of payment, credit card number,
credit card security code or card verification code, credit card expiration
date, and other information which may be necessary to process such transactions. This
information is collected and processed by an external payment processor; it is
not accessed or stored by Base Camp Trading. This Personal Data is required to
provide products and/or Services to you. If you do not provide Personal Data we
ask for, it may delay or prevent us from providing products and/or Services to


Member Information: If a user registers to become a trial member or member, we create
an account in the name of that individual. To establish and maintain such
a trial membership or membership we may request identifying information,
payment information, and addition information necessary to establish or
maintain your account.
Only the minimum amount of information necessary to establish or
maintain the account is mandatory. To access the user account, the registrant
is required to choose a password.


Communication from Users: When a user completes an online form, visits our Platform, or
otherwise contacts us by email, phone or text, we automatically collect and
store certain information about that user and the user’s activities, such as:
name and contact information, information
the user provides us, user’s company information (if any), nature of the
communication, purpose of the interaction, action taken by Base Camp Trading or
user in response to the user’s  inquiry or request, and/or demographic information.


Communications to Users: Unless we are prohibited by applicable law from using cookies or a
user has not otherwise consented to our use of cookies, we insert cookies in
some of our correspondences which allow us to determine whether a user has
accessed or declined to open our message and count other unique clicks or
visits. This information helps us understand how the user reacts to our


Surveys and Contests: From time-to-time, we invite users to participate in surveys or
contests. Participation is voluntary. When a user participates, we collect and
store your responses to such surveys, contests, and promotions. Depending on
the nature of the survey or contents, we also use this information to send the
survey results to the participants, or, if applicable, to notify contest
winners and award prizes. We also use the information in aggregate form, for
analytics purposes, to understand our market, to monitor site traffic or app
usage, or to modify our Platform or our Service to meet the needs or interests
of users.


If we use a third-party service provider to conduct these surveys,
the information collected by the service provider is subject to both the
service provider’s privacy policy and ours. We will provide information about
the applicable privacy policies with the survey rules and will seek your
explicit consent to these rules when required by law. You should read the terms
of the survey or contest to understand the extent to which the service provider
is allowed to use or reuse the information collected.


Social Media: Our Platform offers integrations with third-party social media
platforms. These services collect, at a minimum, the user’s IP address and
which page of our Platform the user is visiting. They may set a cookie to
enable their features to function properly. Social media features and widgets
are hosted by a third party or directly on our Platform. Your interactions with
these features are governed by the privacy policy of the company providing the


Publicly Available Data: We collect information available from publicly accessible
sources, such as property records or information about a user’s interests.


Information Provided by Users: Certain areas of the Platform allow you to write messages to
other users or post content, which such messages or posts may contain Personal
Data. You should be aware that information so disclosed or shared will be
generally available to other persons, both inside of and/or outside of the
Platform, who have access to such areas of the Platform. All such information
is disclosed or shared at a user’s own risk. All user opinions contained in
such messages or posts do not reflect the opinions of Base Camp Trading. We
request that you do not disclose:

  • Any data revealing your racial or
    ethnic origin, political opinions, religious or philosophical beliefs,
    genetic data, biometric data or data concerning your health, sex life or
    sexual orientation.
  • Any identifying
    data, including social security number, national identification number,
    financial account information or any other sensitive or confidential
  • Any data
    (including identifying data) related to other persons.


Log Data: When
a user uses or interacts with our Platform, or clicks on a link that directs
the user to our Platform, the user’s browser automatically provides, and we automatically
collect and store, certain information about the user’s device and the user’s
activities, such as:

  • Preferences and settings:  Time zone, language,
    character size, etc.
  • Identifiers:
    IP address.
  • Technical information:
    Device information, operating system and version, browser information,
    screen resolution, etc.
  • Coarse Geographic information: General geographic location
    derived from the IP address.

collect this data for the proper operation of our Platform. Until the user
registers with us, this data cannot be linked to a specific individual.


Traffic Data: Data
generated through a user’s use of the Platform, such as: pages viewed, time
spent per page, data of page visit(s),
URL of the last webpage visited before visiting a page of our Platform, click through and clickstream data, search history, search results selected; comments made, type of service requested, purchases made.



of Processing Personal Data

data protection law (including the European Union General Data Protection
Regulation (“GDPR”)), we can only use your Personal Data if we have a proper
reason for doing so.
use Personal Data for the following purposes:




provide products and Services to users and to perform our obligations under any
contract with you;


take steps at your request before entering into a contractual relationship with
a user;


allow members to create and maintain their account, verify the member’s
identity and assist a user in the event of lost or forgotten login or password;


respond to user inquiries, allow users to sign up for newsletters, and request
white papers or other information;


interaction on social media; and


develop new products and services features.




provide marketing information regarding Base Camp Trading’s products and Services,
or those of selected third parties (as allowable by applicable law) to
potential and existing users and/or members;


To understand
our market and promote our business, including through market research and


provide information in which a user has indicated an interest; and


To send
marketing communications regarding products and services that are identical or similar to those a user has previously purchased or requested via the Platform.




create a profile of a person as a Platform user (including through
the use of
profiling cookies) in order to provide information, advertisements and offerings of Services relevant to that user.


Operational Reasons


develop and administer the Platform;


improve Base Camp Trading’s offerings and Services;


enhance user’s(s’) experience;


To troubleshoot
any technical issues; and


To be
as efficient as we can to deliver the best Services and information to you.


Misuse or Fraud


prevent and detect any fraud against you or Base Camp Trading, misuse of the
Platform, or any fraudulent or criminal activities carried out through the Platform;


verify the identity of our customer, members and users;


ensure the confidentiality of commercially sensitive information;


unauthorized access and modifications to systems; and


ensure our business policies are adhered to.


Compliance with Legal and Regulatory Obligations


Gathering and providing information
required by or relating to audits, enquiries or investigations by regulatory


To ensure safe working practices, staff
administration and assessments;


To perform/comply with external audits
and quality checks; and


Other processing necessary to comply with professional, legal and
regulatory obligations that apply to our business.




and Promotional Considerations

We may use your Personal Data to
send you updates (
by email, text message,
telephone or post) about our products and Services, including exclusive offers,
promotions or new products and/or Services.


We have a legitimate interest in processing your Personal
Data for promotional purposes (see above “Purposes of Processing”). This means
we do not usually need your consent to send you promotional communications.
However, where consent is needed, we will ask for this consent separately and


You have the right to opt out of receiving
promotional communications at any time by:

• Contacting us at [email protected];

• Using the “unsubscribe” link in emails or “STOP” number in texts; or

• Updating your marketing preferences in your member or trial member account settings.

may ask you to confirm or update your marketing preferences if you request
further products and/or Services in the future, or if there are changes in the
law, regulation, or the structure of our business.



of Personal Data

We use our best efforts to only share your Personal Data fairly,
lawfully, and proportionately in light of the legitimate interests and needs of our business, our legal obligations, and our obligations under our contracts. Our practices are intended to address each individual’s legitimate rights and expectations in view of the context and purpose of the collection and use of the information collected; without being intrusive or contrary to individuals’ rights.
you would like more information about who we share our data with and why,
please contact us (see “How to Contact Us” below). In
light of
the foregoing, we share Personal Data with:


Marketing Partners

In countries where such activities do not require prior explicit
consent of a user, we provide Personal Data to third party marketing companies,
advertising agencies, and data aggregation companies. These third parties use such
Personal Data to provide individuals with information on products and services
of interest. In countries, such as in the EEA, where such activities are
restricted, we conduct these activities in accordance with applicable local


Service Providers

We share information with our suppliers, subcontractors, and other
third parties who provide services to us to help use run our business (such as
hosting services, data analytics providers, insurers, our banks, external
auditors, and information technology providers), to help us deliver our
products and Services to you (such as payment service providers, warehouses,
order fulfillment, delivery (physically or digitally) companies, and related
activities necessary to provide the products or perform the Services, and as
necessary to comply with our legal or contractual obligations. We provide only
the information such service providers need to perform their designated
functions. Our contracts with them prohibit them from using or sharing with
others the information that we provide to them.


Affiliated Entities

We share information with our affiliates (i.e., entities that are
under common ownership or control of Base Camp Trading). Subject to local law
requirements, express preferences indicated by individuals, or our contractual
obligations, this information is used to promote services offered by our affiliates
and for the purposes described in this Privacy Policy.


Third Parties Approved by Users

We share Personal Data with third parties
approved by you, including social media sites you choose to link to your
account to or third-party payment providers.


Law Enforcement; Fraud Prevention; and Protection of Legal Rights

We use and disclose information to the appropriate credit
reporting, legal, judicial or law enforcement authorities and our advisors and
investigators (i) when we believe, in our sole discretion, that such disclosure
is necessary to comply with our legal and regulatory obligations; to investigate,
prevent, or respond to suspected illegal or fraudulent activity; or to protect
the safety, rights, or property of Base Camp Trading, its customers, members,
trial members, visitors, users, or others; (ii) Data if a court, law
enforcement or other public or government authority with appropriate
jurisdiction so requests, and we believe, in our reasonable discretion, that
such request was made in compliance with applicable law; (iii) when an
individual has abused the Platform and/or Services, exceeded the permitted use
of the Platform and/or Services, gained unauthorized access to the Platform
and/or any Services, engaged in spamming, denial of service attacks, use of
malicious code, or similar attacks; (iv) to exercise or protect legal rights or
defend against legal claims; or (v) to allow us to pursue available remedies or
limit the damages that we sustain.


Corporate Reorganization

We transfer Personal Data to a third party in case of the
reorganization, sale, merger, joint venture, assignment, transfer or other
disposition of all or any portion of our business, asset or stocks, including
in the event of bankruptcy or corporate restructuring. Except as otherwise
provided by a bankruptcy or other court, the use and disclosure of all
transferred Personal Data will be subject to policies that are consistent with
the policies described in this Privacy Policy. Any information that any
individual submits or that is collected after that transfer is subject to a new
privacy policy adopted by the successor entity.



Date We Sold or Disclosed for a Business Purpose

We have not sold to a third party
any Personal Data that identifies, relates to, describes, is capable of being
associated with, or could reasonably be linked, directly or indirectly, with a
particular consumer or household.


However, in the preceding 12
months, we have disclosed for a business purpose to one or more third parties
the following categories of Personal Data:


Identifiers (e.g., a real name, alias, postal address, unique
personal identifier, online identifier, Internet Protocol address, email
address, account name, social security number, driver’s license number,
passport number, or other similar identifiers).


Information that identifies, relates to, describes, or
is capable of being associated with, a particular individual, including, but
not limited to, name, signature, social security number, physical
characteristics or description, address, telephone number, passport number,
driver’s license or state identification card number, insurance policy number,
education, employment, employment history, bank account number, credit card
number, debit card number, or any other financial information, medical
information, or health insurance information;


Characteristics of protected classifications under
California or federal law;


Commercial information (e.g., records of personal
property, products or services purchased, obtained, or considered, or other
purchasing or consuming histories or tendencies);


Biometric information;


Internet or other electronic network activity
information (e.g., browsing history, search history, and information regarding
a consumer’s interaction with an Internet Web site, application, or


Geolocation data;


Audio, electronic, visual, thermal, olfactory, or
similar information;


Professional or employment-related information;


Education information, defined as information that is
not publicly available personally identifiable information as defined in the
Family Educational Rights and Privacy Act (FERPA); and


Inferences drawn from any of the information
identified above to create a profile about a consumer reflecting the consumer’s
preferences, characteristics, psychological trends, predispositions, behavior,
attitudes, intelligence, abilities, and aptitudes.


of Personal Data

Personal Data may be held at our offices and those of our third-party
agencies, services providers, and representative as described above (see above,
“Recipients of Personal Data”). Generally, we retain Personal Data we collect
from you as long as we have an ongoing legitimate business need to do so, including:


To provide you with a product or Service you have requested;


As necessary to fulfill our contractual obligations;


To maintain your accounts and memberships with us;


To comply with legal, tax or accounting requirements and maintain
records as required by law;


To respond to questions and complaints made by your or on your


To resolve disputes; and


To enforce our agreements.

We will not retain your
Personal Data for longer than necessary for the purposes set out in this
Policy. We will delete, anonymize or otherwise discard user data (including
Personal Data and all other data) we collect about you while using our Platform
when it is no longer necessary to retain such information or when you contact
us to do so. You can initiate such a request by contacting our customer service
department (see below, “How to Contact Us”).



In some countries, the law requires us to provide you with
detailed information about the cookies that are stored on your device when you
access, visit or otherwise use our Platform or Service(s). The law also
requires that we obtain your consent to the use of certain types of cookies.
This cookie policy aims to provide you with information about cookies, how we
use them, and when applicable law how we request your consent.


What are “cookies”?

Cookies are small bits of data we store on the device you use
to access our services so we can recognize repeat users. They are used for
numerous different purposes, including to remember a user’s actions and
preferences (for example, login data, language, font size, other display
settings, etc.), so that the user does not have to configure them again when
visiting the Platform, or when moving from page to page within a website.
Some operations within a website will not be able to be performed without
the use of cookies which, in certain cases, are technically necessary for
operation of the website. They also contain a unique ID code that allows
tracking a user’s browsing activities within a website, for statistical or
advertising purposes.


Technical/Functional Cookies

For some types of cookies, the consent of the user is unnecessary.
This is the case for “technical cookies” and “functional cookies” which are
only used to send messages through an electronic communication network, are
needed to provide the user with the service that the user requests, are used to
allow the user to login, and are used to remember choices made by a user when
accessing the Platform, such as language, fonts, settings, or to remember the
products selected for purchase. These cookies are essential for the proper
operation of the functions offered by the Platform.


Cookies present on the Platform

We use the following types of cookies:

Browsing or session cookies: We use browsing or session cookies as
necessary for the operation of the Platform, and/or to allow the user to access
and use the content of the Platform and the Services.

Analytics cookies: We use Google Analytics to collect information
that permits evaluation of the use of the Platform, and analysis of user’s
behavior and improvement of user experience. Information about how to opt out
of being tracked by Google Analytics is available at:

Technical/Functional cookies: We use functional cookies to
activate specific functions and to configure webpages according to the user’s
preference such as font size or language.

Profiling cookies:  We use profiling cookies to observe a
user’s interest based on activities on a website, and to send advertisements
that take these preferences into account. You may opt-out of being tracked by
these cookies

Third party cookies: We use third party cookies, owned by third
parties to allow the collection of information about you so that we can send
advertisements to you when you visit other websites. You may opt-out of being
tracked by these cookies. Please notes that opting out of receiving
interest-based advertising does not block all advertisements served to your
device. You will continue receiving advertisements, but these advertisements
will be generic or based on the content of a webpage that you are visiting,
instead of being targeted to your specific interests.

Users Located in the EEA

Pursuant to the EU Cookie Law and the GDPR, we can store cookies
on your device that are essential to the operation of the Platform, such as
functional cookies.
For all other, non-essential
types of cookies, we need prior consent from users located in the EEA.


How we Obtain your Consent (for users in the EEA)

The first time you visit our Platform or at any other time after
you have deleted our cookies from your device, you will be presented with a
notice informing you that the Platform uses cookies. We will only use
non-essential cookies if you express your consent by clicking on the appropriate
box. If you decide to continue through our Platform after being presented with
that notice, without clicking on the appropriate box, we will assume that we do
not have your consent to set cookies as described in this policy.

Disabling or blocking cookies

You can block our Platform from setting cookies and can delete
cookies at any time by modifying the settings of your browser. Please review
the “Help” section of your browser.


CAUTION:  If you block or delete technical and/or functional
cookies used by the Platform, the Platform may become impossible to browse,
certain services or functions of the Platform may become unavailable or other
malfunctions may occur.




We use commercially reasonable technical, organizational,
physical, managerial, and administrative safeguards to protect information
within our control against unauthorized or unlawful access, use, modification,
destruction, processing or disclosure, and against accidental loss,
destruction, or damage. We limit access to our users’ Personal Data to only
those who have a genuine business need to access it.
Those processing your information will do so only in an authorized
manner and are subject to a duty of confidentiality.


Please be aware, however, that no data security measures can be
guaranteed to be completely effective. Consequently, Base Camp Trading cannot
ensure or warrant the security of collected data or other information. In particular, we cannot guarantee that collected data or other information will not be disclosed, altered, or accessed in accidental circumstances or by unauthorized or unlawful acts of others.


We also have procedures in place to deal with any
suspected data security breach. We will notify you and any applicable regulator
of a suspected data security breach where we are legally required to do so.


If you have reason to believe that the security of your account or
Personal Data might have been compromised, if you suspect someone else is using
your account, or if your credit, bank, other financial institution information,
username or password is lost, stolen or used without permission, contact us
immediately as indicated in the “How to Contact Us” section.


10.  Transfers of Personal Data

Base Camp Trading operates its technology from servers located in
the United States and the information it collects through clients is processed
solely in the United States. Laws governing the collection and use of data in
the EEA or United States may not be equivalent to those in the country where
you reside, but we will at all times protect your data in accordance with this Policy.


We may share your information with our affiliates and other third
parties described above who are based in countries outside of your country of
residence. In such circumstances, we will take all reasonable measures to
protect your information in accordance with this Privacy Policy and all
applicable legal requirements.


If any of the recipients is located in a country without the adequate legal protection or safeguards for Personal Data, Company will make reasonable efforts to cause the recipient adopts the principles described in this Privacy Policy.



Rights of Individuals Located
in the European Economic Area

The GDPR grants individuals who are in the EEA the following
rights, with some limitations. Users may contact us, at the address provided in
the “How to Contact us” section below, to exercise any of those rights and we
will respond with the requested action or information or will let you know why
that right does not apply to you.


Right of Access: You have the right to request a copy of your Personal Data. We may
charge you a small fee for this service.


Right of Rectification: You have the right to request that we correct any Personal Data you
believe is inaccurate, and that we complete Personal Date you believe is incomplete.


Right of Erasure: In certain circumstances, you have the right to request that we
erase your Personal Data; for example, if it is no longer necessary for the
purposes for which it was originally collected.


Right to Restrict Processing: In certain circumstances, you have the right to request that we
restrict the processing of your Personal Data; for example, where you believe
that such Personal Data is inaccurate.


Right to Data Portability: In certain circumstances, you have the right to request that we
transfer your Personal Data that we have collected to you or to another
organization in a structured, commonly used, machine readable format.


Right to Object to the Processing: You
have the right to object:

At any time to your Personal
Data being processed for direct marketing and/or profiling; and

In certain circumstances, to
our continued processing of your Personal Data.

Right Not to be Subject to Automated Individual Decision-Making: In certain circumstances, you
have the right not to be subject to a decision based solely on automated
processing – including profiling – that produces legal effects or similarly
affects you.



Rights of Users Who Are
California Residents

The California Consumer Privacy Act (“CCPA”) and other applicable
California state privacy laws provide California residents with specific rights
regarding their Personal Data free of charge, including the following:


Right to Know Personal Data We Collect About You: You have the right to request
that we disclose certain information to you about our collection and use of
your Personal Data over the past 12 months. Once we receive and confirm your
verifiable consumer request, we will disclose to you:

The categories of Personal Data collected about you.


The categories of sources from which we collected Personal Data
about you.


Our business or commercial purpose for
collecting, using or selling your Personal Data.


The categories of third parties with whom we
share such Personal Data.


The specific pieces of Personal Data we have collected
about you.


If we sold or disclosed your Personal Data for
a business purpose, two separate lists disclosing:


Categories of Personal Data about you that we
sold, and the categories of third parties to whom the Personal Data was sold;


Categories of Personal Data we disclosed about
you for a business purpose.

note that we are not required to:

Retain any of your Personal Data
that was collected for a single one-time transaction if, in the ordinary course
of business, that information about you is not retained;

Reidentify or otherwise link
any data that, in the ordinary course of business, is not maintained in a
manner that would be considered Personal Data; or

Provide your Personal Data to
you more than twice in a 12-month period.

Right to Opt-Out of
the Sale of Personal Data:
If you are a California resident, you
have the right under the CCPA and certain other privacy and data protection
laws, as applicable, to opt-out of the sale of your Personal Data. If you
exercise your right to opt-out of the sale of your Personal Data, we will refrain
from selling your Personal Data, unless you subsequently provide express
authorization for the sale of your Personal Data. To opt-out of the sale of
your Personal Data, send an email with the request to [email protected].

Right to Deletion: You have the right to request that we delete any of your Personal Data
that we collected from you and retained, subject to certain exceptions. Once we
receive and confirm your verifiable consumer request, we will delete (and
direct our service providers to delete) your Personal Data from our records,
unless an exception applies. We may deny your deletion request if retaining the
information is necessary for us or our service provider(s) to:


Complete the transaction for which we
collected the Personal Data, provide a good or Service that you requested, take
actions reasonably anticipated within the context of our ongoing business
relationship with you, or otherwise perform our contract with you;


Detect security incidents,
protect against malicious, deceptive, fraudulent, or illegal activity, or
prosecute those responsible for such activities;


Debug to identify and repair
errors that impair existing intended functionality;


Exercise free speech, ensure
the right of another consumer to exercise their free speech rights, or exercise
another right provided for by law;


Comply with the California
Electronic Communications Privacy Act (
Cal. Penal Code § 1546 et. seq.


Engage in public or
peer-reviewed scientific, historical, or statistical research in the public
interest that adheres to all other applicable ethics and privacy laws, when our
deletion of the information is likely to render impossible or seriously impair
the research’s achievement, if you previously provided informed consent;


Enable solely internal uses
that are reasonably aligned with consumer expectations based on your
relationship with us;


Comply with a legal obligation;


Make other internal and lawful
uses of that information that are compatible with the context in which you
provided it.

Right to Non-Discrimination: You
have the right to not be discriminated against by us because you exercised any
of your rights under the CCPA. This means we cannot, unless permitted by the
CCPA, among other things:


goods or services to you;


different prices or rates for goods or services, including through the use of
discounts or other benefits or imposing penalties;


a different level or quality of goods or services to you; or


that you will receive a different price or rate for goods or services or a
different level or quality of goods or services.

note that we may charge a different price or rate or provide a different level
or quality of goods and/or Services to you, if that difference is reasonably
related to the value provided to our business by your Personal Data.


Shine the Light

Under California law, a business that has an established business
relationship with an individual, and has, within the immediately preceding
calendar year, disclosed Personal Data that is primarily used for personal,
family or household purposes to third party for the third party’s direct
marketing purposes, must disclose to its California users, upon request, the
identity of any such third party, along with the type of Personal Data
disclosed. You can contact us as provided in the “How to Contact Us” section to
obtain such information. Please note that under California law, businesses are
only required to respond to a user’s request once during any calendar year.



Since there is no widely accepted standard for “Do Not Track” signals,
we have not yet developed features that would recognize or respond to browser
initiated Do Not Track signals.



How to Exercise Your Rights

To exercise any of your rights as
described in this Policy, please email or write to us at the email address and
address listed in the “How to Contact Us” section below. Only you, or a person
registered with the California Secretary of State that you authorize to act on
your behalf, may make a verifiable consumer request related to your Personal Data.
You may only make a verifiable consumer request for access or deletion once
within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to
reasonably verify you are the person about whom we collected Personal Data
information or an authorized representative.

Describe your request with sufficient detail that
allows us to properly understand, evaluate, and respond to it.

Include your full name, email address and phone number
so we may process your request in an efficient manner.

Making a verifiable consumer
request does not require you to create an account with us. However, we do
consider requests made through your password protected account sufficiently
verified when the request relates to Personal Data associated with that
specific account.
We are not obligated to make a
data access or data portability disclosure if we cannot verify that the person
making the request is the person about whom we collected information or is
someone authorized to act on such person’s behalf.


We will only use Personal Data
provided in a verifiable consumer request to verify the requestor’s identity or
authority to make the request.


We do not charge a fee to process
or respond to your verifiable consumer request unless it is excessive,
repetitive, or manifestly unfounded. If we determine that the request warrants
a fee, we will tell you why we made that decision and provide you with a cost
estimate before completing your request.



How to File a GDPR Complaint

We hope that we or our Data Protection Officer can resolve any
query or concern you raise about our use of your information. The GDPR also
gives you right to lodge a complaint with a supervisory authority in the EEA
state where you work, normally live, or where any alleged infringement of data
protection laws occurred.



Children’s Privacy

Our Platform is not directed to individuals under the age of 18. We
do not solicit or knowingly collect Personal Data from such individuals. If you
become aware that a child has provided us with Personal Data, please contact us
as indicated in the “How to Contact Us” section below. If we obtain actual
knowledge that we have collected Personal Data from a child under the age of
18, we will take steps to delete such information from our database.




We may revise this Privacy Policy at any time. Such changes,
modifications, additions or deletions shall be effective immediately upon
notice thereof. We may provide notice of any material change to this Privacy
Policy directly on this page, by prominently displaying notice of changes on
our homepage, and/or by sending an email to the email address listed by
registered users. We encourage you to visit this page periodically to review
our current privacy policy so that you will always know what information we
gather and how we may use that information. Your continued use of the site
after such modifications will constitute your: (a) acknowledgment of the
modified Policy; and (b) agreement to abide and be bound by the modified



How to Contact Us 

We are committed to resolving questions and complaints about our
collection or use of your Personal Data. Inquires or complaints regarding this
Privacy Policy should contact Base Camp Trading at:


                [email protected]




                811 Sixth Street, Suite 220

                Wichita Falls, TX 76301.