Privacy Policy

January 10, 2019

We recognize the importance of keeping the information you (“you” or “your”) provide to us

private and secure. This Policy applies, in general, to all Internet sites operated by or on behalf of

us (the “Site”) and related services (the “Services”).

1. User Consent.

By using our Site or providing Personal Information to us, you are consenting to the collection, use

and disclosure of your Personal Information as described in this Policy. If you do not consent to

the collection, use and disclosure of your Personal Information as described in this Policy, do not

use our Site.

2. Types of Information We Collect.

When we refer to "Personal Information" we mean information that allows someone to identify or

contact you, including, for example, your name, address, telephone number, e-mail address, as

well as any other non-public information about you that is associated with or linked to any of the

foregoing information. When we refer to "Anonymous Information" we mean information that is

not associated with or linked to your Personal Information and which cannot be identified as

belonging to you.

We may collect Personal Information from you, such as your first and last name, mailing address,

phone number, e-mail address, billing address, credit card or debit card information, PayPal

account, and similar information when you create an account. Our Site may collect information

from you, including your browser type, operating system, IP address, web pages visited, web

pages viewed, buttons or links clicked, time spent on website, time spent on web pages, etc.

3. Use of Your Personal Information.

Whenever we collect Personal Information on our Site, we will:

• not disclose, transfer, sell or otherwise provide your Personal Information to any third

party unless required by law or as expressly stated herein;

• provide timely and appropriate notice to you about our data practices through this Privacy

Policy Statement;

• collect and use your Personal Information only with your consent, which may be express or

implied, depending on the sensitivity of the Personal Information, legal requirements, and

other factors;

• collect your Personal Information only for specific, limited purposes. The information we

collect will be relevant, adequate and not excessive for the purposes for which it is

collected;

• process your Personal Information in a manner consistent with the purposes for which it

was originally collected or to which you have subsequently consented; and

• not use your Personal Information for direct marketing purposes without giving you an

opportunity to “opt-out”.

We may use Personal Information:

• to create your membership or user profile account and provide the Services you request;

• to access the third party services you specifically request access to;

• to register you for a webinar or online workshop or streaming workshop;

• to place transactions or orders to purchase software, research or membership access;

• to provide support and assistance for email requests or questions related to our Services;

• to the extent you choose to participate, to conduct questionnaires and survesy in order to

provide better Services and Products;

• to personalize marketing communications and website content based on your preferences,

access level, user level, Services purchased;

• to provide improved administration of our Site and Services including billing, mailing,

email, phone number, name updates or edits;

• to send you administrative e-mail notifications and other Services related communications;

• to send newsletters, surveys, offers, and other promotional materials related to our

Services and for other marketing purposes;

• to contact you regarding opportunities to compensate you for your algorithm's

performance;

• to share anonymized and/or aggregated algorithm performance statistics with third

parties, for example potential investors or for marketing purposes; and

• to market our products and services (and those of third parties) to you that we believe may

be of interest, both on and off the Site.

• to facilitate communication with other Members of the Site as you direct us through the

Services.

4. Control and Retention of Personal Information.

We will periodically send you free newsletters and e-mails that directly promote the use of our

Site or Services. When you receive newsletters or promotional communications from us, you may

indicate a preference to stop receiving further communications from us and you will have the

opportunity to "opt-out" by following the unsubscribe instructions. Even if you opt-out of

receiving marketing related email messages, we will continue to send you service related

communications, including notices related to your Account or any updates to our Terms of Use or

Privacy Policy. We retain the Personal Information collected on our Site as long as necessary to

provide the services, products and information you request or as permitted by applicable law.

5. Security of Personal Information.

Your Personal Information will generally be stored in our or our servers (which are hosted by a

third party service provider) located in the United States. To the extent required by law, if your

Personal Information will be transferred outside of this country, an appropriate notice will be

provided. We maintain safeguards to protect the confidentiality, security and integrity of your

Personal Information. However, as is the case with all computer networks linked to the Internet,

we cannot guarantee the security of information provided over the Internet and will not be

responsible for breaches of security unless we have acted in a grossly negligent manner.

6. Use of Anonymous Information.

We may create Anonymous Information records from Personal Information by excluding any

information that makes the information personally identifiable to the data subject. We use this

Anonymous Information to so that we may enhance the content of our Services and improve Site

performance. We reserve the right to use Anonymous Information for any purpose and disclose

Anonymous Information to third parties at its sole discretion.

7. Third Party Service Providers.

We use software plugins and other third-party plugins on this site in order to facilitate and support our

business and users. These plugins include payment gateways and other payment transaction processors,

analytics and website tracking software, membership management and access delivery software,

commenting and forum software, marketing and promotion software as well as video, audio, content, and

social media plugins. The current list of active software plugins and third-party plugins we use on this site

include: Google Analytics, Facebook, LinkedIn, Instagram, Vimeo, Pinterest, Stripe, PayPal, Disqus,

OptimizePress, Co-Schedule, SEO Yoast, YouTube, Sumo, Amazon Web Services, Digital Ocean, Comodo

Security Services, GoDaddy, Kraken Image Optimizer, Muut, Nav Menu Roles, My Page Order, Postman

SMTP, Pretty Links, Really Simple SSL, Scarcity Builder, ShiftNav, Smart Podcast Player, UpdraftPlus,

Askimet Anit-Spam, AnsPress, Sensei, WPBakery, AffiliateWP, EasyTables, Font Awesome, Post Expirator,

Remove Query Strings, Thrive Quiz Builder, TinyMCE, Visual Composer, We Total Cache, WordPress

Importer, WP User Avatar, WebinarJam, Demio, SpeakPipe, OptinMonster, Join.me, LeadPages, SendHub,

Calendly, SoundCloud, Libsyn, iTunes, GooglePlay, iHeart Radio, Stitcher, ActiveCampaign, MailChimp,

PushCrew,

In general, the third-party providers used by us will only collect, use and disclose your information to the

extent necessary to allow them to perform the services they provide to us as already outlined in the "We

may use Personal Information" section above. However, certain third-party service providers, such as

payment gateways and other payment transaction processors, have their own privacy policies in respect to

the information we are required to provide to them for your purchase-related transactions. For these

providers, we recommend that you read their privacy policies, so you can understand the manner in which

your personal information will be handled by these providers. In particular, remember that certain providers

may be located in or have facilities that are located a different jurisdiction than either you or us. So, if you

elect to proceed with a transaction that involves the services of a third-party service provider, then your

information may become subject to the laws of the jurisdiction(s) in which that service provider or its facilities

are located.

In certain, limited circumstances we may required share or transfer Personal Information to other

unrelated third parties. For example, we may provide Personal Information to a third party: (i) at

your request; (ii) to comply with a legal requirement or court order; (iii) to investigate a possible

crime, such as identity theft; (iv) in connection with the sale, purchase, investment in, merger,

reorganization, liquidation or dissolution of our company or business; or (v) under similar

circumstances. If such an event occurs, we will take appropriate steps to protect your Personal

Information.

8. Third Party Websites.

Our Site may contain links to Internet sites that are not operated by us. These links are provided

as a service and do not imply any endorsement of the activities or content of these sites, nor any

association with their operators. We do not control these Internet sites and we are not and cannot

be responsible for their content, security, or privacy practices. We urge you to review the privacy

policy posted on those other websites you visit before using the site or providing Personal

Information.

9. Use of Cookies.

We use cookies on this site. We may link the information we store in cookies to any personally

identifiable information you submit while on our site. We may use both session ID cookies and

persistent cookies. We may use session cookies to make it easier for you to navigate our site. A

session ID cookie expires when you close you browser. A persistent cookie remains on your hard

drive for an extended period of time. You can remove persistent cookies by following directions

provided in your Internet browser’s “help” file. If you reject cookies, you may still use our site.

Some of our business partners (e.g., our analytics provider) may use cookies on our site. We have

no access to or control over these cookies. This privacy statement covers the use of cookies by us

only and does not cover the use of cookies by any such firm. A cookie is a small text file that is

stored on a user’s computer for record-keeping purposes.

10. Users Outside of the United States.

If you are a non U.S. user of the Site or Services, by visiting the Site and/or providing us with

information, you acknowledge and agree that your Personal Information may be processed for the

purposes identified in the Privacy Policy. In addition, your Personal Information may be processed

in the country in which it was collected and in other countries, including the United States, where

laws regarding processing of Personal Information may be less stringent than the laws in your

country. By providing your information, you consent to such transfer.

11. Security

We take reasonable measures to help protect information about you from loss, theft, misuse, and

unauthorized access, disclosure, alteration, and destruction.

Transfer of Information to the U.S. and Privacy Shield

We are based in the United States and the information we collect is governed by U.S. law. By accessing or

using the Service or otherwise providing information to us, you consent to the processing, transfer, and

storage of information in and to the U.S. and other countries, where you may not have the same rights and

protections as you do under local law.

We comply with the EU-US Privacy Shield Framework and the Swiss-US Privacy Shield

Framework as set forth by the US Department of Commerce regarding the collection, use,

and retention of personal information from European Union member countries and

Switzerland transferred to the United States pursuant to Privacy Shield. We have certified

that we adhere to the Privacy Shield Principles with respect to such data. If there is any

conflict between the policies in this privacy policy and data subject rights under the

Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about

the Privacy Shield program, and to view our certification page, please visit

https://www.privacyshield.gov/

With respect to personal data received or transferred pursuant to the Privacy Shield

Frameworks, We are subject to the regulatory enforcement powers of the U.S. Federal

Trade Commission.

Pursuant to the Privacy Shield Frameworks, EU and Swiss individuals have the right to

obtain our confirmation of whether we maintain personal information relating to you in the

United States. Upon request, we will provide you with access to the personal information

that we hold about you. You may also may correct, amend, or delete the personal

information we hold about you. An individual who seeks access, or who seeks to correct,

amend, or delete inaccurate data transferred to the United States under Privacy Shield,

should direct their query to team@optionalpha.com. If requested to remove data, we will

respond within a reasonable timeframe.

We will provide an individual opt-out or opt-in choice before we share your data with third

parties other than our agents, or before we use it for a purpose other than which it was

originally collected or subsequently authorized. To request to limit the use and disclosure

of your personal information, please submit a written request to team@optionalpha.com.

In certain situations, we may be required to disclose personal data in response to lawful

requests by public authorities, including to meet national security or law enforcement

requirements.

Our accountability for personal data that we receive in the United States under the Privacy

Shield and subsequently transfers to a third party is described in the Privacy Shield

Principles. In particular, we remain responsible and liable under the Privacy Shield

Principles if third-party agents that it engages to process the personal data on its behalf

do so in a manner inconsistent with the Principles, unless we prove that we are not

responsible for the event giving rise to the damage.

In compliance with the Privacy Shield Principles, we commit to resolve complaints about

your privacy and our collection or use of your personal information transferred to the

United States pursuant to Privacy Shield. European Union and Swiss individuals with

Privacy Shield inquiries or complaints should first contact us by email at

team@optionalpha.com or via post at:

Option Alpha / Alta5

Attn: Privacy

1600 West Ave #301

Miami, FL 33139

We have further committed to refer unresolved privacy complaints under the Privacy

Shield Principles to an independent dispute resolution mechanism, the BBB EU PRIVACY

SHIELD, operated by the Council of Better Business Bureaus. If you do not receive timely

acknowledgment of your complaint, or if your complaint is not satisfactorily addressed,

please visit www.bbb.org/EU-privacy-shield/for-eu-consumers for more information and to

file a complaint. This service is provided free of charge to you.

If your Privacy Shield complaint cannot be resolved through the above channels, under certain

conditions, you may invoke binding arbitration for some residual claims not resolved by other

redress mechanisms. See Privacy Shield Annex 1 at

https://www.privacyshield.gov/article?id=ANNEX-I-introduction

12. Your Rights and Choices Under GDPR

Account Information

You may update, correct or delete information about you at any time by requesting such deletion at

team@optionalpha.com.

You may exercise your right to withdraw your consent to the Service at any time. The withdrawal of consent

will require deactivation of your account. To withdraw consent and deactivate your account, please contact

support at team@optionalpha.com. If you wish to exercise your right to data portability or right to erasure,

please email us at team@optionalpha.com, but note that we may retain certain information as required by

law or for legitimate business purposes.

We may also retain cached or archived copies of information about you for up to 12 months. You have the

right to lodge a complaint with a supervisory authority.

You may also have the right to make a GDPR complaint to the relevant Supervisory Authority. A list of

Supervisory Authorities is available here: http://ec.europa.eu/justice/dataprotection/

bodies/authorities/index_en.htm. If you need further assistance regarding your rights, please

contact us using the contact information provided below and we will consider your request in accordance

with applicable law. In some cases our ability to uphold these rights for you may depend upon our

obligations to process personal information for security, safety, fraud prevention reasons, compliance with

regulatory or legal requirements, or because processing is necessary to deliver the services you have

requested. Where this is the case, we will inform you of specific details in response to your request.

13. Children.

Our Services and Site are not directed to children and children are not eligible to use our Services.

Protecting the privacy of children is very important to us. We do not collect or maintain Personal

Information from people we actually know are under 13 years of age, and no part of our Site or

Services is designed to attract people under 13 years of age. If we later learn that a user is under

13 years of age, we will take steps to remove that user's Personal Information from our databases

and to prevent the user from utilizing the Site and the Services.

14. Changes in this Privacy Statement.

If we decide to change our privacy policy, we will post those changes to this privacy statement, the

homepage, and other places we deem appropriate so that you are aware of what information we

collect, how we use it, and under what circumstances, if any, we disclose it. We reserve the right

to modify this privacy statement at any time, so please review it frequently. If we make material

changes to this policy, we will notify you here, by email, or by means of a notice on our home page.

15. Contact Us.

If you have any questions or suggestions regarding our privacy policy, please contact us at

team@optionalpha.com, or mail us at:

Option Alpha / Alta5

Attn: Privacy

17 Palermo Ave

Coral Gables, FL 33134

Notice to California Residents:

If you are a California resident, California Civil Code Section 1798.83 permits you to request information

regarding the disclosure of your Personal Information by High Fidelity to third parties for the third parties'

direct marketing purposes. With respect to these entities, this Privacy Policy applies only to their activities

within the State of California. To make such a request, please send an e-mail to team@optionalpha.com or

write us at the address listed immediately above.

Last Revised: January 10, 2019