Privacy Policy

Iconic Exchange Limited t/a Blue Guardian (“BLUE GUARDIAN”) respects your privacy and is

committed to ensuring that consumers who access our website and/or use or access products or

services offered by us (“you” or “your”) are informed regarding the way their personal data is

used. This Privacy Statement applies to our website www.blueguardian.com (“Site”) and BLUE

GUARDIAN affiliates, subsidiaries, parent companies, and any other related entities (hereinafter

collectively “BLUE GUARDIAN”, “we” or “us”), and all products and services offered by BLUE

GUARDIAN, and governs personal data collection and usage by us. For the purposes of this

GUARDIAN include the Site and BLUE GUARDIAN. By using the Site, you consent to the data

practices described in this Statement and all revisions or amendments made to this Statement from

time to time. BLUE GUARDIAN provides assistance to individuals with disabilities to

communicate effectively with them. Please contact BLUE GUARDIAN by visiting our website at

https://www.blueguardian.com/contact and use the contact form to send us a message.

Collection of your Personal Information

We collect information about you in a variety of ways depending on how you interact with us, the

Site, and our services, including:

1. Directly from you when you provide it to us, such as when you register for an account, sign

up to receive communications from us, start a service, or contact us by phone, email, or

otherwise;

2. Automatically through the use of cookies, server logs, and other similar technologies when

you interact with the Site, promotional material, advertisements and emails; and

3. From other sources, including, for example, our affiliates, business partners, service

providers, online social media networks, and other third parties, or from publicly available

sources. For example, if you submit a job application, or become an employee, we may

conduct a background check.

In order to better provide you with products and services offered, we may collect personally

identifiable information, such as the following, which sets forth the types of personal information

we collect and how we use the information:

Context Types of Data Primary Purpose for Collection/Use of

Data

Demo Account

Registration

We may collect your name, financial information, and contact information

when you create an account. We also collect information relating to the actions that you perform while logged into your account.

We have a legitimate interest in providing account related functionalities to our users and preventing illegal conduct.

Biometric Identifiers We may collect certain biometric information about you, such as imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as

We are required to collect this information to meet our legal obligations and have a legitimate interest in doing so and preventing fraud. a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns, or rhythms, and sleep, health, or exercise data that contain identifying information.

Client Information We collect the names and contact information of our clients and their employees with whom we may interact.

We have a legitimate interest in contacting our clients and communicating with them concerning normal business administration such as projects, services, and billing.

Cookies and First-

Party Tracking

We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed.

We have a legitimate interest in making our website operate efficiently.

Cookies and Third-

Party Tracking

We may place tracking technology on our website that collects analytics, records how you interact with our website, or allows us to participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can report analytics to us or provide advertising about products and services tailored to your interests. That third party might also collect information over time and across different websites in order to serve advertisements on our website or other websites.

Where required by law, we base the use of third-party cookies upon consent.

Demographic

Information

We collect personal information, such as your date of birth, race or location.

We have a legitimate interest in ensuring our users are legitimate and to prevent fraudulent and illegal activity.

Interconnectivity

If you receive email from us, we use certain tools to capture data related to when you open our message, click on any links or banners it contains and make purchases.

We have a legitimate interest in understanding how you interact with our communications to you.

Employment If you apply for a job posting, or become an employee, we collect information necessary to process your application or to retain you as an employee. This may include, among other things, your Social Security Number. Providing this information is required for employment.

We use information about current employees to fulfil our obligations to employees. In some contexts, we are also required by law to collect information about employees or applicants. We also have a legitimate interest in using your information to have efficient staffing and work force operations.

Feedback/Support If you provide us feedback or contact us for support, we will collect your name and email address, as well as any other content that you send to us, in order to reply.

We have a legitimate interest in receiving, and acting upon, your feedback or issues.

Mobile Devices We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website or when visiting one of our stores.

We have a legitimate interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.

Order Placement We collect your name, billing address, email address, phone number, and credit card number when you place an order.

We use your information to perform our contract to provide you with products or services.

Partner Promotion We collect information that you provide as part of a co-branded promotion with another company.

We have a legitimate interest in fulfilling our promotions.

Surveys When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third-party service provider, the third party’s privacy policy applies to the collection, use, and disclosure of your information.

We have a legitimate interest in understanding your opinions and collecting information relevant to our organization.

Sweepstakes or contests

When you participate in a sweepstakes or contest, we collect information about you which includes contact information to notify you if you are selected.

We have a legitimate interest in operating the sweepstakes and contests. In some contexts, we are also required by law to collect information about those that enter into our sweepstakes and contests, and we have a legitimate interest in complying with those laws.

Website interactions We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.

We have a legitimate interest in understanding how you interact with our website to better improve it, and in understanding your preferences and interests to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.

Web logs We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.

We have a legitimate interest in monitoring our networks and the visitors to our websites.

Among other things, it helps us understand which of our services is the most popular.

We collect this data and provide it to third parties, as discussed below, if it is a necessary step in

the user’s account creation process, contributes to the ease of use, reliability, security, or

functionality of our products. If you purchase BLUE GUARDIAN’s products or services, we

collect billing and credit card information. This information is used to complete the purchase

transaction or issue payments to you.

You may be required to provide certain personal information to us when you elect to use certain

products or services. We also may gather additional personal or non-personal information in the

future for the same purpose.

Use of your Personal Information

We collect and use your personal information to:

1. Operate and deliver the products or services you have requested.

2. We may also use your personally identifiable information to inform you of other products

or services available from BLUE GUARDIAN and its affiliates.

3. To identify you when you visit our Sites or use our products or services.

4. To improve our services and product offerings.

5. To conduct analytics.

6. To communicate with you, such as to respond to and/or follow-up on your requests,

inquiries, issues, or feedback.

7. To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including

violations of our Terms of Use, other policies, security incidents, and harm to the rights,

property, or safety of our company and our users, employees, or others.

8. To debug, identify and repair errors that impair existing intended functionality of our

website and services.

9. To comply with our legal or regulatory obligations, to establish or exercise our rights, and

to defend against a legal claim.

10. For internal administrative purposes, as well as to manage our relationships.

11. For such other purposes as you may consent (from time to time).

Although the sections above describe our primary purpose in collecting your information, in many

situations, we have more than one purpose. As a result, our collection and processing of your

information may be based in different contexts depending on your consent, our need to fulfill a

contract, our obligations under the law, and/or our legitimate interest in conducting our business.

You explicitly consent to share your data with BLUE GUARDIAN and/or our affiliates, simulated

trading platforms, mentorship programs, mentors, or third parties for the purposes of detecting

fraudulent, deceptive, malicious, or criminal behavior or any violations of our Terms or this

Agreement.

Sharing Information with Third Parties

In addition to the specific situations discussed elsewhere in this Statement, we may disclose

personal information in the following situations:

1. Affiliates and Acquisitions. We may share information with our corporate affiliates (g.,

parent company, sister companies, subsidiaries, joint ventures, or other companies under

common control). If another company acquires, or plans to acquire, our company, business,

or our assets, we will also share information with that company, including at the negotiation

stage.

2. Other Disclosures without Your Consent. We may disclose information in response to

subpoenas, warrants, or court orders, or in connection with any legal process, or to comply

with relevant laws. We may also share your information in order to establish or exercise

our rights, to defend against a legal claim, to investigate, prevent, or take action regarding

possible illegal activities, suspected fraud, safety of person or property, or a violation of

our policies, or to comply with your request for the shipment of products to or the provision

of services by a third-party intermediary.

3. Public. Our website may provide the opportunity to post comments, or reviews, in a public

forum. If you decide to submit information on these pages, that information may be

publicly available.

4. Service Providers. We may share your information with service providers. Among other

things service providers may help us to administer our website, conduct surveys, provide

technical support, process payments, and assist in the fulfillment of orders.

5. Other simulated trading platforms and mentors. We may share information with

simulated trading platforms, mentorship programs, mentors, and/or related affiliates in

order to detect and protect against malicious, deceptive, fraudulent, or illegal activity or

violations of our Terms of Use, and other policies.

6. Other Disclosures with Your Consent. We may disclose your information to other third

parties when we have your consent or direction to do so.

Tracking User Behavior

BLUE GUARDIAN may track and record the websites and pages our users visit within BLUE

GUARDIAN, in order to determine what BLUE GUARDIAN services are the most popular. This

data is used to deliver customized content and advertising within BLUE GUARDIAN to customers

whose behavior indicates that they are interested in a particular subject area.

Automatically Collected Information

Information about your computer hardware and software may be automatically collected by BLUE

GUARDIAN. This information can include: your IP address, browser type, domain names, access

times and referring website addresses. This information is used for the operation of the service, to

maintain the quality of the service, and to provide general statistics regarding use of the Site.

Use of Cookies

The Site may use “cookies” to help you personalize your online experience. A cookie is a text file

that is placed on your hard disk by a web page server. Cookies cannot be used to run programs or

deliver viruses to your computer. Cookies are uniquely assigned to you and can only be read by a

web server in the domain that issued the cookie to you.

One of the primary purposes of cookies is to provide a convenience feature to save you time. The

purpose of a cookie is to tell the Web server that you have returned to a specific page. For example, if you personalize BLUE GUARDIAN pages, or register with the Site or services, a cookie helps the Site to recall your specific information on subsequent visits. This simplifies the process of recording your personal information, such as billing addresses, shipping addresses, and so on.

When you return to the Site, the information you previously provided can be retrieved, so you can

easily use the features that you customized.

You have the ability to accept or decline cookies. Most Web browsers automatically accept

cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you

choose to decline cookies, you may not be able to fully experience the interactive features of the

Site when you visit. Additionally, depending on where you live, you may have the right to restrict

certain cookies using the cookie banner on the Site.

Third-Party Links

The Site contains links to other sites. Please be aware that we are not responsible for the content

or privacy practices of such other sites. We encourage our users to be aware when they leave our

Site and to read the privacy statements of any other site that collects personally identifiable

information.

Security and Retention of your Personal Information

We take reasonable security measures to protect against unauthorized access to or alteration of

your personal information. Notwithstanding the foregoing, no data transmission over the Internet

or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to

protect your personal information, you acknowledge that: (a) there are security and privacy

limitations inherent to the Internet which are beyond our control; and (b) security, integrity, and

privacy of any and all information and data exchanged between you and us through the Site cannot be guaranteed. In the event that we are required by law to inform you of a breach to your personal information we may, at our discretion, notify you electronically, in writing, or by telephone, if permitted to do so by law.

Our Site permits you to create an account. If you create an account on the Site, you will be

prompted to create a password. You are responsible for maintaining the confidentiality of your

password, and you are responsible for any access to or use of your account by someone else that

has obtained your password, whether or not such access or use has been authorized by you. You

should notify us of any unauthorized use of your password or account.

We retain your personal information for only as long as necessary to fulfil the purposes outlined

in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting

requirements, unless a longer retention period is required or permitted by law. To determine the

appropriate retention period for personal information, we consider the amount, nature, and

sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the

information, the purposes for which we obtained the information, and whether we can achieve

those purposes through other means, as well as applicable legal requirements.

Your Choices

Subject to certain exceptions, and only for those individuals who meet specific jurisdictional and

legal requirements, you have the right to make the following requests:

1. Access to Your Personal Information. You may request access to your personal

information or confirmation that we have information about you. In certain limited

circumstances, you may also request to receive access to your data in a portable, machinereadable

format.

2. Changes to Your Personal Information. We rely on you to update and correct your

personal information. Our Site will allow you to modify or delete your account profile. If

our Site does not permit you to update or correct certain information, you can contact us at

the address described below to request that your information be modified. You may ask us

to correct information that is inaccurate or incomplete. Note that we may keep historical

information in our backup files as permitted by law.

3. Deletion of Your Personal Information. You may request that we delete your personal

information. If required by law, we will grant a request to delete information, but you

should note that in many situations we must keep your personal information to comply

with our legal obligations, resolve disputes, enforce our agreements, or for other business

purposes.

4. Opt-out of Selling or Sharing for Targeted Advertising. You may opt out of online

tracking-based targeted advertising (e.g., cookies) by clicking the “Reject” button in the

“We value your privacy” window. Please note that if you change browsers or computers,

or if you clear your browser’s cache, you may need to click the link again to apply your

preference. You can also reject cookies on our cookie banner. Please note that not all

sharing or disclosure of your personal information is a “sale” and not all sharing or

disclosure is subject to the right to opt out.

5. Objection to Certain Processing. You may object to our use or disclosure of your

personal information by contacting us at the address described below.

6. Online Tracking. We do not currently recognize the “Do Not Track” signal.

7. Promotional Emails. From time to time, BLUE GUARDIAN may contact you via email

for the purpose of providing announcements, promotional offers, alerts, confirmations,

surveys, and/or other general communication. If you would like to stop receiving marketing

or promotional communications via email from BLUE GUARDIAN, you may opt out of

such communications by clicking on the “unsubscribe” button found at the bottom of each

email.

8. Revocation of Consent. Where we process your personal information based upon consent,

you may revoke consent. Please note, if you revoke your consent for the processing of

personal information then we may no longer be able to provide you with the Services.

To exercise any of your rights, please contact BLUE GUARDIAN by visiting our website at

https://www.blueguardian.com/contact and use the contact form to send us a message. In some

circumstances, you may authorize an agent to exercise your rights by sending us a message on

your behalf. If you use an agent to submit an opt out request, you must provide the agent with

signed written permission demonstrating that they have been authorized by you to act on your

behalf. We may require more information to ensure proper verification of your and your agent’s

identity and authorization. Depending on your request, we will ask for information such as your

name, information about the last interaction you had with us, or the date of your last purchase from us. We may also ask you to provide a signed declaration confirming your identity. If you are

utilizing an agent, we require a signed and notarized permission from you stating that the agent

has authorization to act on your behalf. We will deny the request if we are unable to verify the

requestor or the authorized agent.

Changes to this Statement

BLUE GUARDIAN reserves the right to amend this Policy from time to time. We will notify you

about significant changes in the way we treat personal information by sending a notice to the

primary email address specified in your account, by placing a prominent notice on our website,

and/or by updating any privacy information. Your continued use of our website and/or Services

available after any such modifications will constitute your: (a) acknowledgment of the revised

Policy; and (b) agreement to abide and be bound by such Policy as revised.

Contact Information

BLUE GUARDIAN welcomes your questions or comments regarding this Statement. If you have

any questions or comments, please visit our website at https://www.blueguardian.com/contact and

use the contact form to send us a message.

Additional Information For California Residents

California law requires us to disclose the following additional information related to our privacy

practices. If you are a California resident, the following privacy disclosures apply to you in

addition to the rest of the Privacy Policy.

• California Shine the Light. If you would like more information concerning the categories

of personal information (if any) we share with third parties or affiliates for those parties to

use for direct marketing, please submit a written request to us using the information in

the Contact Information section above.

• Notice of Collection. The table below describes the categories of personal information we

collect, disclose for a business purpose, “sell” and/or “share” (as those terms are defined

by California law). Please note, in addition to the recipients identified below, we may

disclose any of the categories of personal information we collect with government entities,

as may be needed to comply with the law or prevent illegal activity. BLUE GUARDIAN

may sell or lease customer information to third parties for the following reasons:

o BLUE GUARDIAN may, from time to time, contact you on behalf of

external business partners about a particular offering that may be of interest

to you. In those cases, your unique personally identifiable information (email,

name, address, telephone number) is transferred to the third party.

o BLUE GUARDIAN may, if we in our discretion consider it potentially

beneficial to you, share personal data or information with our affiliates or

trusted third-party partners in order to provide you with further educational,

marketing and promotional offers we believe may be of interest to you. You

are always entitled to opt-out from receiving such offers.

• Fraud Prevention. You explicitly consent to BLUE GUARDIAN sharing your personal

information with other proprietary simulated trading firms, mentorship programs, mentors,

or third parties for the purposes of detecting fraudulent, deceptive, malicious, or criminal

behavior or any violations of our Terms or this Agreement.

In order to better provide you with products and services offered, we may collect personally

identifiable information, such as the following, which sets forth the types of personal information

we collect and how we use the information:

Category of Personal

Information Category of Recipients Disclosures for Business Purposes Sharing for Cross-Context

Behavioral Advertising

Sales Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, Demo Account name, or other similar identifiers.

Affiliates or subsidiaries
Business partners
Data analytics providers
Data brokers
Internet service providers
Joint marketing partners
Operating systems and platforms
Other service providers
Payment processors and financial institutions
Professional services organizations – this may include auditors and legal counsel
Social networks
Business partners
Joint marketing partners
Business Partners
Joint marketing partners

Government Issued Identification – this may include social security number, driver's license number, or state issued identification number, passport number.

Service providers
Professional services organizations – this may include auditors and legal counsel

None

Financial Information – this may include bank Demo Account number, credit card number, debit card number, and other financial information.

Affiliates or subsidiaries
Business partners
Internet service providers
Operating systems and platforms
Other service providers
Payment processors and financial institutions
Professional services organizations – this may include auditors and legal counsel

None

Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical, or mental handicap, etc.

Service providers
Payment processors and financial institutions
Professional services organizations – this may include auditors and legal counsel

None

Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

Affiliates or subsidiaries
Business partners
Data analytics providers
Data brokers
Internet service providers
Joint marketing partners
Operating systems and platforms
Other service providers
Payment processors and financial institutions
Professional services organizations, this may include auditors and legal counsel
Social networks
Business partners
Joint marketing partners
Business partners
Joint marketing partners

Biometric information – this may include imagery of the iris, retina, fingerprint, face, hand, palm, vein patterns, and voice recordings, from which an identifier template, such as a faceprint, a minutiae template, or a voiceprint, can be extracted, and keystroke patterns or rhythms, gait patterns, or rhythms, and sleep, health, or exercise data that contain identifying information

Service providers

None

Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual's interaction with an internet website, application, or advertisement.

Affiliates or subsidiaries
Business partners
Data analytics providers
Data brokers
Internet service providers
Joint marketing partners
Operating systems and platforms
Other service providers
Payment processors and financial institutions
Professional services organizations, this may include auditors and legal counsel
Social networks
Business partners
Joint marketing partners
Business partners
Joint marketing partners

Geolocation data

Affiliates or subsidiaries
Business partners
Data analytics providers
Data brokers
Internet service providers
Joint marketing partners
Operating systems and platforms
Other service providers
Payment processors and financial institutions
Professional services organizations, this may include auditors and legal counsel
Social networks
Business partners
Joint marketing partners
Business partners
Joint marketing partners

Professional or employment-related information

Affiliates or subsidiaries
Business partners
Data analytics providers
Data brokers
Internet service providers
Joint marketing partners
Operating systems and platforms
Other service providers
Payment processors and financial institutions
Professional services organizations, this may include auditors and legal counsel
Social networks

None

Inferences drawn from any of the information listed above

Affiliates or subsidiaries
Business partners
Data analytics providers
Data brokers
Internet service providers
Joint marketing partners
Operating systems and platforms
Other service providers
Payment processors and financial institutions
Professional services organizations, this may include auditors and legal counsel
Social networks
Business partners
Joint marketing partners
Business partners
Joint marketing partners

Additional categories of personal information described in the California Customer Records statute (Cal. Civ. Code §1798.80(e)) – this may include signature, physical characteristics, or description,

Affiliates or subsidiaries
Business partners

3. Data analytics providers

4. Data brokers

5. Internet service providers

6. Joint marketing partners None None insurance policy number.

7. Operating systems and platforms

8. Other service providers

9. Payment processors and financial institutions

10. Professional services organizations, this may include auditors and legal counsel

11. Social networks

• California Sensitive Information Disclosure. We collect the following categories of

sensitive personal information (as defined under California law): your biometric data. This

information is collected to process transactions, comply with laws, manage our business,

or provide you with services. Note that we do not use such information for any purposes

that are not identified within the California Privacy Rights Act Section 1798.121. We do

not “sell” or “share” sensitive personal information for purposes of cross-context

behavioral advertising.

Last Update: August 30, 2024.

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