CQG Privacy Notice

To operate effectively and provide you with the best experience possible, CQG¹ sometimes collects data and information from individuals who use our services or visit our website. We may collect information through the CQG website, via our customer service team, or through your interaction with our products. CQG collects this data to provide you with the services you need and to continually work to improve our products. At the same time, CQG values your privacy. As a result, we have developed this Privacy Policy to explain how we collect, use, transfer, disclose, and store your information. Please review the details, and let us know if you have any questions.

What information does CQG collect?

CQG generally collects and uses two types of information from people who visit our website or access our services: personal information and non-personal information. Personal information is data that can be used to identify or contact a particular person. Non-personal information is information that, on its own, does not permit direct association with any particular person. Generally, there is no collection, storage, or processing of personal or non-personal information, except as described in this policy.

How does CQG use or share personal information?

When you interact with the CQG website or CQG services, CQG may collect, use, and share some types of personal information. Specifically, if you register with our website, contact us, or purchase and use CQG products or services, we may collect a variety of information from you, including your name, address, phone number, email address, IP address, credit card information, professional status, and trading account data. We may share your personal information with the following:

• CQG subsidiaries and affiliates, which are located in multiple countries around the world.
• CQG’s contractors, service providers, and other third parties we use to support our business.
• CQG’s brokers, futures commissions merchants, or other clearing firms with whom you (expressly or impliedly) grant permission to share information.
• Other entities to fulfill the purpose for which you have specifically provided the information.
• A buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, when personal information held by us is treated as an asset transferred.
• For any other purpose disclosed by us when you provide the information.

CQG may also disclose your personal information:

• To comply with any court order, law or legal process, including to respond to any government or regulatory request.
• To enforce or apply our agreements with you, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect our rights, property, or safety, our customers or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Sometimes we use third party service partners to sign up a user, bill a user, or to facilitate the provision of services pursuant to the specific terms of our user agreements. If you sign up for these services, we may share your personal information necessary for the third party to provide these services. When you provide us with personal information to complete a transaction, verify your credit card, place an order, or otherwise engage with our products or services, we assume you consent to our collection and use of information shared for that specific reason. We may also disclose your personal information if we are required by law, as discussed above.

How does CQG use or share non-personal information?

CQG may also collect, use, and share some types of non-personal information. For example, CQG uses cookies on our website. A cookie is a piece of data stored on a hard drive containing information about the user. Usage of a cookie is in no way linked to any personal information while on our site. If you reject the cookie, you may still use our site. Similarly, CQG may use IP addresses to analyze trends, administer the site, and track movement on the website. Sometimes IP addresses are not linked to personal information, and in some cases they are.

We also use Google Analytics to collect data about the use of our website to better serve our audience. This Google Analytics data is not combined with personal information. Google’s use of information that is collected by Google Analytics during visits to our site is governed by the Google Privacy Policy. To prevent Google Analytics from recognizing you on future visits, disable the Google Analytics cookie on your browser.

Not all of our website and services respond to your browser’s “do-not-track” signals or comparable mechanisms. Generally, however, we only collect non-personal information via the CQG website (except when forms are completed and submitted to CQG).

Can I opt out of information collection or request a correction to my information?

Yes. You may opt out of the collection of certain personal information by CQG. You may also request access to and correct your personal information held by CQG. We will make reasonable efforts to correct errors in personal information within thirty (30) days of receipt of a correction request. To request correction, opt out, or learn more about our personal information policies, email privacy@cqg.com.

What about links within the CQG website or products?

Our website contains links to other sites. Please be aware that CQG is not responsible for the privacy practices of other such sites. As a result, we encourage you to be aware when you leave our site and to read the privacy statements of each and every website that collects personally identifiable information. Our privacy policy, as it relates to the CQG website, applies solely to information collected by this website.

What happens if CQG changes the Privacy Policy?

If we decide to change our privacy policy, we will post those changes, so you are always aware of what information we collect, how we use it, and under what circumstances, if any, we share it with others.

Is there anything else I should know?

CQG is based in the United States with offices around the globe. Please know that if you share personal information with CQG, it may be transferred to any CQG facility. We recognize that many customers access CQG products and services from outside of the United States. CQG strives to ensure compliance with all applicable data protection laws, rules, and regulations. Consistent with various international frameworks, CQG respects the fundamental principles of privacy: notice, choice, access, security, data integrity and purpose limitation, and accountability. CQG incorporates these values into all aspects of our service, including ensuring the security and integrity of any information you share with us.

What if I still have questions?

CQG is always happy to answer any questions you have about our commitment to privacy and the security of your information. You can contact privacy@cqg.com with any questions.

Effective Date: June 2018

¹ “CQG” means CQG, Inc., as well as its subsidiaries and affiliates.

² CQG is committed to information security, including security of personal information. Please see our CQG Information Security Statement for more details.