WFCM WEBSITE PRIVACY POLICY

This Privacy Policy (“Privacy Policy”) is effective as of March 12, 2023.

Wen Futures Capital Management, LLC (“WFCM,” “we” or “us”) respects your (“you,” “your” or “User”) concerns about privacy. This Privacy Policy applies to personal information we obtain about individuals (other than WFCM personnel), including on WenFuturesCapital.com.com, WFCM.com and other WFCM-owned websites (collectively, “Website”). In our Privacy Policy, we describe the types of personal information we obtain, how we may use the information and the purposes for which we may use it, with whom we may share it and the choices available to you. We also describe the measures we take to safeguard the information and tell you how to contact us about our privacy practices.

If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement.”

Information We Obtain

WFCM may obtain personal information about you in various ways, such as through our Website. The types of information we obtain include:

Contact information, such as your name, postal address, e-mail address, and telephone number;
Username and password to access WFCM products and services online;
Personal trading details and information obtained from brokerage accounts;
Information that we obtain about you when you apply for a job with us, such as information about your education, work and military history, legal work eligibility status, citizenship status, background check information, information collected for diversity monitoring purposes, and other information;
If you are a consultant or contingent worker of WFCM, or a representative of our vendors or other business partners, information we obtain about you in the course of your professional relationship with us, such as professional and employment-related data, vaccine status and other information designed to protect the health and safety of our staff and others, and medical or religious information if you request a workplace accommodation; and
Other personal information you voluntarily provide to us, such as your preferences or data provided through online forms.

When you use our Website or view our emails, WFCM will, itself or through a third party vendor, automatically collect technical and usage data pertaining to your device and/or Internet connection. Such data includes the number and frequency of your visits to the Website, information regarding websites accessed immediately before and after your visit to the Website, information about the content you viewed, your Internet browser type, your preferences on the Website, your IP address and your device characteristics. We use this data to (1) remember your information so you will not have to re-enter it; (2) track and understand how you use and interact with the Website; (3) personalize your visit to the Website; (4) measure the usability of the Website and the effectiveness of our communications; and (5) otherwise manage and enhance the Website. This technical and usage data is obtained using cookies, web beacons, web server logs and other similar technologies. Cookies are small text files that websites send to your computer or other Internet-connected device to identify your browser and to store information or settings in the browser. A “web beacon,” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server. Your browser may tell you how to be notified when you receive certain types of cookies or how to restrict or disable certain types of cookies. Please note, however, that without cookies you may not be able to use all of the features of our Website. For mobile devices, you can manage how your device and browser share certain device data by adjusting the privacy and security settings on your mobile device or browsers. For more information, please review our Cookie Usage Information.

We may combine information we collect from you with information we receive from third parties and use it for the purposes described in this Privacy Policy. We also may use information we obtain about you in other ways for which we provide specific notice at the time of collection.

How We Use the Information We Obtain

We may use the information we obtain about you to:

Provide our products and services;
Communicate with you (and, where required by applicable law, we will obtain your explicit consent to do so);
Establish and manage our business relationships;
Manage career opportunities at WFCM, including for recruitment purposes, candidate screening and evaluation, and employee onboarding;
Managing our professional relationship with consultants, contingent workers and our business partners;
Personalize your experience with us, including on our Website;
Perform analytics (including market research, trend analysis, financial analysis, and anonymization of personal information);
Operate, evaluate, develop, manage and improve our business (including operating, administering, analyzing and improving our Website, products and services; developing new products and services; managing and evaluating the effectiveness of our communications; and performing other internal functions);
Maintain and enhance the safety and security of our Website, products and services, and prevent misuse;
Protect against, identify and prevent fraud and other criminal activity, claims and other liabilities; and
Comply with and enforce applicable legal requirements, relevant industry standards and policies.

In compliance with relevant law, we may retain information as needed or appropriate to serve our legitimate business purposes or as required by law.

Third-Party Analytics Services

We use third-party web analytics services on our Website, such as those of Google Analytics and Wistia. The analytics providers that administer these services use technologies such as cookies, web server logs and web beacons to help us analyze how visitors use the Website. The information collected through these means (including IP addresses) is disclosed to these analytics providers, who use data to evaluate use of the Website.

For more information about these third-party analytics cookies, please review our Cookie Usage Information.

Online Tracking and Interest-Based Advertising

For more information about these third-party advertising cookies, please review our Coo kie Usage Information.

Our Website is not designed to respond to “do not track” signals received from browsers.

Disclosures of Information

We do not share personal information about you except as described in this Privacy Policy. We share your personal information with our affiliates for the purposes identified in this Privacy Policy. We also share your personal information with agents and service providers. We do not authorize these agents or service providers to retain, use or disclose the personal information except as necessary to perform services on our behalf or comply with legal requirements.

We also may disclose personal information about you (1) if we are required to do so by law or legal process (such as a court order or subpoena); (2) in response to requests by government agencies, such as law enforcement authorities; (3) to establish, exercise or defend our legal rights; (4) when we believe disclosure is necessary or appropriate to prevent physical or other harm or financial loss; (5) in connection with an investigation of suspected or actual illegal activity; or (6) otherwise with your consent.

We reserve the right to share or transfer any personal information we have about you in connection with a prospective or actual sale, merger, transfer or other reorganization of all or parts of our business (including in the event of a divestiture, restructuring, reorganization, dissolution or liquidation).

Your Choices

To opt out of receiving direct marketing communications, such as commercial emails, or to unsubscribe from our services, please contact us at Privacy(at) WenFuturesCapital.com.com.

If you are a California consumer, for more information about your privacy rights, please see the section of this Policy called “California Consumer Privacy Statement.”

Security

WFCM maintains administrative, technical and physical safeguards designed to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

Other Online Services and Third-Party Features

For your convenience and information, our Website may contain links to other online services, and may include third-party features such as apps, tools, widgets and plug-ins. These online services and third-party features may operate independently of WFCM. The privacy practices of these third parties, including details on the information they may collect about you, is subject to their own privacy policies or notices, which we strongly suggest you review. We are not responsible for the content of any online services that are not affiliated with WFCM, any use of those services, or the privacy practices of those services.

The providers of third-party apps, tools, and plug-ins on our Website also may use automated means to collect information regarding your interactions with these features. For example, when we present videos on our Website, we may use YouTube as a third-party platform provider, which uses cookies independent of our own. These third parties may collect information about your online activities over time and across third-party websites. This information is collected directly by the providers of the features and is subject to the privacy policies or notices of these providers. To the extent permitted by applicable law, we are not responsible for these providers’ information practices. For more information about YouTube and their use of cookies, please visit https://policies.google.com/technologies/cookies.

Updates To This Privacy Policy

This Privacy Policy may be updated periodically and without prior notice to you to reflect changes in our information practices and applicable law. We suggest that you periodically review the Privacy Policy for amendments.

How To Contact Us

If you have any questions about this Privacy Policy, please contact us at Privacy(at)WenFuturesCapital.com.com.

California Consumer Privacy Statement

This California Consumer Privacy Statement supplements the WFCM Privacy Policy and applies solely to California consumers. This Statement does not apply to personnel of either WFCM or our clients.

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”) and the California Privacy Rights Act of 2020 and its implementing regulations (the “CPRA”) (collectively, the “CCPA/CPRA”).

1. Notice of Collection and Use of Personal Information

We may collect (and may have collected during the 12-month period prior to the effective date of this Statement) the following categories of personal information about you:

Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; customer number; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, Social Security number, driver’s license number, passport number, and other similar identifiers
Additional Data Subject to Cal. Civ. Code § 1798.80: signature, physical characteristics or description, state identification card number, education, bank account number and other financial information, and medical information
Protected Classifications: characteristics of protected classifications under California or federal law, such as race, age, sex, gender, gender identity, religion (such as in connection with a lawful vaccination exemption), medical condition, disability, citizenship status, and military and veteran status
Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements
Sensory Information: audio, electronic, visual and similar information
Employment Information: professional or employment-related information
Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use (and may have used during the 12-month period prior to the effective date of this Statement) the categories of personal information listed above for the purposes described in our Privacy Policy. In addition, we may use these categories of personal information for certain business purposes:

Auditing related to counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards
Helping to ensure security and integrity to the extent the use of your personal information is reasonably necessary and proportionate for these purposes
Short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of your current interaction with us
Performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing analytics services, providing storage, or providing similar services
Providing advertising and marketing services to you, except for cross-context behavioral advertising (which is addressed in our Cookie Usage Information)
Debugging to identify and repair errors that impair existing intended functionality
Undertaking internal research for technological development and demonstration
Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us
Managing career opportunities with WFCM
Managing our professional relationship with consultants and contingent workers.

WFCM does not collect or process sensitive personal information with the purpose of inferring characteristics about California consumers covered by this Statement.

To the extent we process deidentified information, we will maintain and use the information in deidentified form and will not attempt to reidentify the information unless permitted by applicable law.

2. Retention of Personal Information

We will retain your personal information for the time period reasonably necessary to achieve the purposes described in our Privacy Policy and this Statement, or any other notice provided at the time of collection, taking into account applicable statutes of limitation and records retention requirements under applicable law.

3. Sources of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have obtained personal information about you from the following categories of sources:

From you, such as when you provide us your contact information in connection with a job opportunity at WFCM or in your capacity as a representative of a business partner or client
From your devices, such as through your interaction with our website
Other individuals, such as in connection with a business referral (e.g., recruiting agencies)
Our affiliates
From your employer, if you are a consultant or contingent worker, or a representative of a vendor or other business partner;
Institutional investors
Financial institutions
Vendors who provide services on our behalf
Recruiting and talent agencies
Background check services;
Public domain sources

4. Sale or Sharing of Personal Information

We do not (and will not) sell or share personal information unless we post a notice of the right to opt out of such sale or sharing and comply with other relevant legal requirements. We do not sell or share sensitive personal information.

5. Disclosure of Personal Information

During the 12-month period prior to the effective date of this Statement, we may have disclosed the following categories of personal information about you for a business purpose to the following categories of third parties:

Category of Personal Information	Category of Third Party
Identifiers	* Background check services * Our affiliates * Vendors who provide services on our behalf * Consultants and professional services organizations, such as auditors and law firms * Recruiting and talent agencies * Employers of consultants or contingent workers * Data analytics providers * Internet service providers * Operating systems and platforms
Additional Data Subject to Cal. Civ. Code § 1798.80 Law	* Background check services * Our affiliates * Vendors who provide services on our behalf * Consultants and professional services organizations, such as auditors and law firms * Recruiting and talent agencies * Employers of consultants or contingent workers
Protected Classifications	* Data analytics providers * Our affiliates * Vendors who provide services on our behalf * Consultants and professional services organizations, such as auditors and law firms * Recruiting and talent agencies * Employers of consultants or contingent workers
Online Activity	* Operating systems and platforms * Our affiliates * Vendors who provide services on our behalf * Consultants and professional services organizations, such as auditors and law firms * Employers of consultants or contingent workers * Data analytics providers * Internet service providers operating systems and platforms
Sensory Information	* Our affiliates * Vendors who provide services on our behalf * Consultants and professional services organizations, such as auditors and law firms * Employers of consultants or contingent workers * Data analytics providers * Internet service providers operating systems and platforms * Operating systems and platforms
Employment Information	* Background check services * Our affiliates * Vendors who provide services on our behalf * Consultants and professional services organizations, such as auditors and law firms * Recruiting and talent agencies * Employers of consultants or contingent workers
Inferences	* Background check services * Our affiliates * Vendors who provide services on our behalf * Consultants and professional services organizations, such as recruiters, auditors and law firms * Employers of consultants or contingent workers * Data analytics providers * Operating systems and platforms

In addition to the categories of third parties identified above, during the 12-month period prior to the effective date of this Statement, we may have disclosed personal information about you to government entities, such as law enforcement authorities, and third parties in connection with actual or proposed corporate transactions, such as mergers, acquisitions or divestitures.

6. California Consumer Privacy Rights

You may have certain choices regarding our use and disclosure of your personal information, as described below.

Access: You may have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.
Correction: You have the right to request that we correct the personal information we maintain about you, if that information is inaccurate.
Deletion: You may have the right to request that we delete certain personal information we have collected from you.
Opt-Out of Sale or Sharing: California law provides consumers with the right to opt-out of the sale of personal information or the sharing of personal information for cross-context behavioral advertising purposes.We do not sell or share consumers’ personal information.

How to Submit a Request: To submit an access or deletion request, call us at 1-469-418-6479. To submit a request as an authorized agent on behalf of a consumer, please email us at privacy@WenFuturesCapital.com.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request. If you do not have an email address or other direct contact information on file with us, then there is no reasonable method by which we can verify your identity to the level of certainty required by the CCPA/CPRA. The reason for this is that WFCM historically has not linked IP addresses, device identifiers or other information collected through automated means to named actual persons. Accordingly, if you do not have an email address or other direct contact information on file with us, and you request access to, correction of or deletion of your personal information, we will not be able to process your request at this time.

If you have an email address or other direct contact information on file with us, and request access to, correction of or deletion of your personal information, we may require you to provide your name, email address, and company name, if previously provided to us. In addition, if you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request.

For questions or concerns about our privacy policies and practices, please contact us as described in the How To Contact Us section of our Privacy Policy.