Privacy Policy

The Wall Street Transcript, Inc. (“TWST”) shares your concern about the protection of your personal information online. This is our Privacy Policy regarding the information we collect on TWST Portfolio of Websites as such term is defined in the Terms of Use. Please note that this Privacy Policy may change from time to time. If changed, we will post an updated Privacy Policy on this page for your review.

Questions or comments regarding this policy should be directed to customersupport@TWST.com.

Information Gathered and Tracked by TWST
We gather two types of data about our users: personal information and tracking information.

PERSONAL INFORMATION
Personal information is provided by users when registering on TWST Portfolio of Websites as a member of TWST, our free flagship site, or another one of our free websites, when registering as a subscriber to one of our premium subscription services, and voluntarily at certain other points, such as entering contests, completing surveys or through any marketing flows. You may enter your information on our site, but if you prefer, you may talk offline to a customer service representative and provide the required information by email at customersupport@TWST.com.

Registering for Membership on TWST
Currently, we do not require users to become members of TWST in order to have access to the free commentary, analysis and news available on TWST.com.

However, if you would like to use certain features, such as email newsletters, or access additional products of TWST Portfolio of Websites, we require you to register to become a member.

In order to register, you will have to supply us with your email address and choose a unique User Name and Password. You will be required to verify your email address by clicking on the activation link in the Welcome Letter that will be sent to you upon your submission of a completed registration form.

Subscribing to Premium Services
If you would like access to one or more of our premium subscription-based services, you will need to supply us with the information specified to activate your free trial or paid subscription. This may include credit card or other payment account information which we may maintain in encrypted form on our servers.

Other Personal Information Collection:

• White Papers – We may offer white papers on various investment and financial topics. In order to download these special reports, you may be required to enter your email address, phone number and/or some additional personal information.
• Blogs – We may offer blogs featuring running commentary throughout the trading day by some of our most popular contributors. These blogs allow subscribers to respond to a blogger’s commentary or to another subscriber’s post. Access to some blogs may require a paid subscription to one of our premium services. We urge and encourage participants posting comments on the blogs to include their full name in any comment and to disclose any positions held in securities they discuss in any comment. Please note that information submitted to the blogs will be available for any user of that service to read, and is no longer private.
• Surveys/Polls – At certain times, you may be asked to participate in surveys, which are generally aimed at obtaining general information, for example, your investment experience or your reaction to a particular article. Because information obtained in these surveys is connected with individual subscribers and is used internally or by third-party partners to better market our services, participation is voluntary. In addition, some columnists will on occasion take polls of their readers. Such polls are solely for the editorial use of the individual columnists, and participation is voluntary.
• Contests and Sweepstakes – We may offer contests or sweepstakes in which certain personal information is required for registration, for purposes of verifying the entrants’ identities and notifying the winners. If the contest or sweepstakes is being administered or sponsored by a third party, this information will be disclosed to that third party. However, entrants may select contest names distinct from their User Names, and the information is not connected with their User Names.

TRACKING INFORMATION
Tracking information is automatically collected about all visitors to TWST Portfolio of Websites. This information consists of both individual and aggregated tracking information and is automatically gathered using “cookies.” A cookie is a small data file containing information, such as a user’s login name, that is written to the user’s hard drive by a web server and used to track the pages visited. Certain websites within TWST Portfolio of Websites are operated by third parties, such third party sites may use cookies or other tracking technology at such sites’s discretion.

We use cookies in several ways to track user behavior. Cookies store visitors’ preferences and past activity on our site and other websites in order to provide better service to our visitors. The information we gather on an individual basis is used for advertising and internal purposes, such as accessing a member’s account information. We also use tracking information on an aggregate basis, to track the readership of stories and usage of our products, to analyze traffic patterns on our sites, and to provide anonymous reporting of usage for internal and external clients. In all cases, cookies used by TWST are encoded and contain a unique digital signature to prevent tampering. They do not contain user passwords. We also employ technology that is commonly referred to as “action tags” (also known as “web beacons,” “scripts” or “one pixel .gif files”) to measure the effectiveness of our advertisements.

We use Google Analytics remarketing codes to log when users view specific pages or take specific actions on our websites. This allows us to provide targeted advertising in the future. If you do not wish to receive this type of advertising from us in the future you can opt out using the Google opt-out page or the Network Advertising Initiative opt-out page.

In addition to the cookies described above, TWST, its agents, advertisers and third-party advertising vendors that serve ads onto our web sites, and other third party partners may use their own or third-party cookies or other tracking technologies for advertising, including delivering targeted advertisements and marketing messages based upon the websites you visit, or other purposes. We cannot be responsible for the privacy policies or practices of third part advertisers and vendors. Additionally, third party advertising vendors, including Google, show our ads on sites on the Internet. If you would like more information about cookies and targeted advertisements or to opt out of having this information used by companies that are part of the Network Advertising Initiative to provide such advertisements, please visit http://www.networkadvertising.org/optout_nonppii.asp.

If you are accessing TWST Portfolio of Websites, you can control your browser’s settings regarding cookies by selecting “Internet Options” or “Preferences” in the menu bar of your browser. This will allow you to prevent your browser from accepting new cookies, have your browser notify you when you receive a new cookie, or disable cookies altogether. However, because cookies allow you to easily navigate our web sites without having to constantly log in using your User Name and Password, we recommend that you leave them turned on. If you are accessing TWST Portfolio of Websites through an alternative method, such as a mobile application or third-party content distribution service, you understand that you may not have the ability to disable cookies, depending on the specific access method.

USE OF THE INFORMATION

• TWST uses the personal information and tracking information obtained from its users as stated in this Privacy Policy, and for the following purposes:
  To enhance users’ experiences on TWST Portfolio of Websites, including the display of customized content and advertising;
• To improve our content;
• To notify visitors about updates to TWST Portfolio of Websites and our Services (as such term is defined in our Terms of Use) and to contact users regarding account maintenance issues in any manner including without limitation, via direct mail, email, telephone or SMS text messages;
• To maintain and improve TWST Portfolio of Websites and our Services;
• To ensure the technical functioning of TWST Portfolio of Websites and our Services; and
• To deliver our Services, as well as free email newsletters containing selected stories, market information, advertisements and links to TWST Portfolio of Websites, or to contact you via direct mail, email, telephone, or SMS text message with information and offers for our Services, as well as special offers and advertisements for products or services offered by third parties. You can select which free newsletters you would like to receive, unsubscribe from delivery of our free newsletters, our marketing messages and third party offers and advertisements at any time by email at customersupport@TWST.com. Please note that if you unsubscribe from communications but subsequently reregister with TWST or enter your email address into any form on TWST Portfolio of Websites, your communication preferences may revert from their unsubscribed status and/or you may receive communications from which you had previously unsubscribed.

Information Sharing
TWST does not sell or disclose personal information about you described above to other people or nonaffiliated companies, except to provide you with products or services, when we have your permission, or under the following circumstances:

• In response to subpoenas, court orders, or legal process, or otherwise to cooperate with law enforcement agencies or state and federal regulators;
• We provide the information to our subsidiaries and affiliated companies;
• We provide the information on a confidential basis to nonaffiliated companies we engage as contractors or agents to perform services for us, such as maintaining software or administering a sweepstakes or contest. Information will be shared with such contractors only to the extent reasonably necessary for them to perform services on our behalf, and pursuant to confidentiality obligations;
• If we sell or otherwise transfer substantially all of our assets related to any web site that we own or operate and any product or service that we offer. In that event, we will require such third party to honor our then-current Privacy Policy, until the third party provides you with notice of changes to our Privacy Policy and permits you to exercise any rights you may have under applicable law to limit disclosures of information about you;
• We may disclose all the information we collect as described above to other companies such as direct marketers to perform marketing services on our behalf, or to third parties with whom we have joint marketing agreements; and
• We may share with third parties certain pieces of aggregated, non-personal information, such as the number of users who clicked on a particular link or how many users clicked on a particular advertisement. Such information does not identify you individually.

PUBLIC FORUMS
Chat rooms, forums, message boards, and/or news groups are available to you through our Web site. Please remember that any information disclosed in these areas becomes public information. If you post personal information online that is accessible to the public, you may receive unsolicited responses. You should exercise caution when deciding to disclose any of your personal information in a public forum.

CORRECTING AND UPDATING THE INFORMATION
TWST offers to its members the ability to correct or update online the information we collected during registration by visiting the Your Account page. You may also contact our customer service department by email at customersupport@TWST.com.

SECURITY
TWST limits access to personal information about you to those employees whom we determine need access to that information to provide products or services to you. We maintain physical, electronic and procedural safeguards that comply with federal standards to guard your personal information. However, no security system is impenetrable. We cannot guarantee the security of our servers, nor can we guarantee that information that users supply will not be intercepted while being transmitted to us over the Internet.

FORMER CUSTOMERS
TWST discloses personal information about former customers only in accordance with this Privacy Policy.

YOUR INDEPENDENT RELATIONSHIPS WITH OTHER COMPANIES
Please note that this Privacy Policy will not apply to your independent relationships with other companies that from time to time may offer you products and services on TWST’s sites. Those companies’ privacy policies will govern how they collect, use and disclose personal information that you provide to them. TWST is not responsible for the privacy practices or content of those websites. We encourage you to review the privacy policy of any company before submitting your personal information.

Questions or comments regarding this policy should be directed to customersupport@TWST.com. TWST reserves the right to modify this policy.