PRIVACY POLICY

POLICY STATEMENT

GURUASP.NET respects customer privacy and is committed to protecting it. Customers can visit most pages on the GURUASP.NET website -- and use all of the currency tools located on our site -- without identifying themselves or providing any personal or financial information. However, if a customer wishes to open an FXTrade account, the law requires the customer to provide GURUASP.NET with certain non-public personal and financial information (referred to as "Personal Information"). The purpose of GURUASP.NET's Privacy Policy is to explain GURUASP.NET's privacy policy and practices and how customer Personal Information is collected, used, disclosed and maintained.

CATEGORIES OF PERSONAL INFORMATION GURUASP.NET COLLECTS

GURUASP.NET collects Personal Information about our customers from the following sources:

• Account Applications and other forms, including customer name, mailing address, Social Security Number, date of birth, employment information, investment experience, annual income, and estimated net worth;
• Customer Transactions with GURUASP.NET, such as account number, account balance and trading activity; Consumer Reports and other information GURUASP.NET receives from third party agencies; and
• "Cookies" described in section "cookies" below.

HOW GURUASP.NET USES CUSTOMER PERSONAL INFORMATION

GURUASP.NET may use Personal Information of current and former customers as necessary to:

• complete bank deposits and withdrawals,
• effect, administer or enforce transactions requested or authorized by the customer, and
• maintain or service the customer's account with GURUASP.NET.

Personal Information collected online may be combined with other information customers provide to GURUASP.NET in hard copy or through the GURUASP.NET help desk. GURUASP.NET will not use or disclose or sell, rent or lease any Personal Information about its customers or former customers to any third parties except as stated in this Policy. Personal Information may be transferred across national and state borders for the purposes of data consolidation, storage and customer data management.

DISCLOSURE OF CUSTOMER PERSONAL INFORMATION

GURUASP.NET may disclose Personal Information of current and former customers to affiliated and non-affiliated third party entities in the following cases:

• to GURUASP.NET's business partners that perform services on GURUASP.NET's behalf under written agreements which restrict use of Personal Information to the limited purposes for which it is provided to them and to refrain from further use or disclosure except as permitted by law;
• to GURUASP.NET affiliates, who are permitted to disclose and use the information only to the extent that GURUASP.NET may disclose and use the information under this Policy;
• in the ordinary course of business to GURUASP.NET's attorneys, accountants and auditors;
• to persons holding a legal or beneficial interest relating to the customer's account;
• to persons acting in a fiduciary, representative, or attorney capacity in relation to an account;
• to protect against actual or potential fraud, unauthorized transactions, claims or other liability;
• to government, regulatory or law enforcement agencies to the extent permitted or required by law, or to comply with applicable legal requirements; or
• to comply with civil, criminal or regulatory investigations, or judicial process, subpoena, summons or warrant by federal, state or local authorities.

PERMISSION TO DISCLOSE PERSONAL INFORMATION

Except as permitted in this Privacy Policy, GURUASP.NET will not share Personal Information about any present or former customer with any non-affiliated third party without the customer's prior written consent or providing the customer with a clear notice, an opportunity to "opt out" of that disclosure, and information on how to opt out.

PROCEDURES TO SAFEGUARD PERSONAL INFORMATION

GURUASP.NET has implemented procedures to safeguard customer Personal Information. GURUASP.NET restricts access to Personal Information to those GURUASP.NET employees who need to know that information in order to provide our products or services to them. GURUASP.NET maintains physical, electronic and procedural safeguards that meet or exceed federal standards to safeguard Personal Information. GURUASP.NET protects customer account information by keeping it on the secure portion of its website, using firewalls and other security technology to protect its network and systems from external attacks, and by requiring customers to enter a unique user ID and password to access the FXTrade and FXGame systems. GURUASP.NET conducts periodic internal audits of its business practices and procedures, examining its confidentiality standards and information access, in order to best protect our customers' Personal Information.

"COOKIES"

GURUASP.NET uses Internet "cookies". Cookies are small amounts of data that the GURUASP.NET website can send to customers' Web browsers to store on their computer. GURUASP.NET uses cookies to facilitate customers' use of the GURUASP.NET website, to store customer preferences for certain kinds of information, and to gather data about the usage of its website for research and other promotions. Cookies set by GURUASP.NET cannot be read by, and are not shared with, any third parties. Our customers can decide if and how their computer will accept a cookie by configuring their preferences or options in their browser. However, if a customer refuses cookies, they may not be able to customize certain of GURUASP.NET's online services or website features, and some FXTrade services may require repeated re-entry of certain data.

LINKS TO NON-GURUASP.NET WEBSITES

The GURUASP.NET website may provide links to third-party websites for customer convenience and information. If customers decide to access those links, they will leave the GURUASP.NET website. GURUASP.NET does not control those third-party sites or their privacy practices, which may differ from GURUASP.NET's. We do not endorse or make any representations about third-party websites. The personal data customers choose to give to unrelated third parties is not covered by the GURUASP.NET Privacy Policy. Customers should review the privacy policy of any third-party website before submitting their personal information. Some third-party companies may choose to share their personal data with GURUASP.NET. That sharing is governed by the disclosing company's privacy policy.

NOTIFICATION OF POLICY AND POLICY CHANGES

GURUASP.NET will provide an initial notice of its Privacy Policy to customers at the time it establishes a customer relationship, and at least annually thereafter, and will post the Policy on its website. Updates will be posted on the GURUASP.NET website, so our customers will always know what information we collect online, how we use it, and what choices they have.

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