top of page

Privacy Policy

Privacy Policy

​

This Privacy Policy explains how CIO Executive Advisors, LLC (“Praedox,” “we,” “us,” “our”) collects, uses, shares, and safeguards information in connection with our websites, software, and services for the NinjaTrader Platform, including Praedox Trader’s Assistant, Praedox Signals, and Praedox Complete (collectively, the “Services”). By using the Services, you agree to this Policy.

​

1) Information We Collect

​

1.1 Information You Provide

  • Account/Checkout: Name, email address (including the email used during checkout), billing details, postal address, and phone number.

  • Orders/Support: Plan selection (monthly or lifetime), products purchased, transaction identifiers, support tickets, and communications.

  • Platform Configuration: Machine IDs, installation details, environment metadata (e.g., NinjaTrader version, broker connection metadata).

  • Preferences/Feedback: Newsletter opt-ins, webinar registrations, surveys, and product feedback.

1.2 Information Collected Automatically

  • Usage: Pages viewed, clicks, time on site, referring/exit pages, and similar analytics.

  • Device/Network: IP address, device identifiers, browser type, OS, timezone, language, crash logs.

  • Cookies/Similar Tech: Cookies, pixels, SDKs, local storage, and beacons to remember settings, authenticate sessions, analyze usage, and measure campaigns.

1.3 Information from Third Parties

  • Payment Processing (Third Party): We use third‑party payment processors to handle payments. We do not collect or store full payment card numbers, CVV codes, or bank account numbers on our systems. The processor provides us limited transaction metadata (e.g., payment status, last 4 digits, expiration month/year, and a token) to complete your purchase and manage billing.

  • Analytics/Ads: Aggregated or pseudonymous audience and campaign metrics from analytics/advertising partners.

  • Platform/Broker: High-level status/compatibility information (not full trading data) needed to operate the Services.

 

2) How We Use Information

​

We use information to:

  • Provide and operate the Services, including licensing on NinjaTrader and Machine ID management.

  • Process orders, billing (via our third‑party payment processor), account management, and customer support.

  • Maintain security, prevent fraud, enforce usage limits, and detect misuse.

  • Improve and develop the Services (analytics, debugging, performance enhancements).

  • Communicate about updates, security notices, and transactions; send marketing where permitted (you can opt out).

  • Comply with legal, regulatory, and audit obligations.

 

3) Cookies, Analytics, and Advertising

​

3.1 How We Use Cookies

  • Essential Cookies (always on): We automatically place essential cookies on visitors’ devices to enable core site features and security (e.g., user logins, session management, checkout/shopping cart, load balancing, fraud prevention). These are necessary for the site to function and cannot be switched off in our systems.

  • Non‑Essential Cookies (consent‑based): Non-essential cookies (e.g., analytics, performance measurement, advertising/retargeting) are used only with your explicit consent. You can grant or withdraw consent at any time via our cookie banner or preferences tool.

3.2 Cookie Banner and Consent

  • Banner and Controls: Our site displays a cookie banner that informs you about the cookies we use and collects your consent for non‑essential cookies. The banner content is configurable and may be tailored to our site’s style and needs.

  • Transparency and Choice: Consistent with GDPR and similar regulations, the banner clearly explains the categories of cookies in use and offers the option to accept, reject, or customize non‑essential cookies. You can revisit your choices at any time through the banner or a site link (e.g., footer) to cookie preferences.

3.3 Analytics and Advertising (if enabled by consent)

  • Analytics: With your consent, we may use analytics cookies to understand traffic patterns, feature usage, and performance. Data collected is typically pseudonymous and aggregated.

  • Advertising/Retargeting: With your consent, advertising cookies/pixels may be used to measure campaign effectiveness and deliver relevant ads. You can adjust ad preferences in the cookie banner/preferences tool and via your browser/platform settings.

  • Opt‑Out: You may opt out of non‑essential cookies at any time using the cookie banner/preferences tool. Essential site features will continue to function if you opt out of non‑essential cookies.

3.4 Managing Cookies

  • Browser Controls: Most browsers allow you to block or delete cookies. Blocking essential cookies may impair site functionality, including login and checkout.

  • Global Privacy Controls: Where required by law, we honor GPC (Global Privacy Control) signals as an opt‑out of “sale/share” for cross‑context behavioral advertising (if applicable).

 

4) Payment Processing (Third Party)

​

  • Processor Role: Payments are processed by a third‑party payment processor acting on our behalf. The processor receives your payment method details directly and stores them, if you opt to save a method for recurring billing.

  • Limited Payment Data to Praedox: We receive only limited payment metadata (e.g., transaction ID, payment status, last 4 digits of card, expiration month/year, payment token) to manage your order and subscription.

  • No Sensitive Financial Data Stored by Praedox: We do not collect or store full payment card numbers, CVV codes, or bank account numbers on Praedox systems.

 

5) How We Share Information

​

We do not sell your personal information. We share:

  • Service Providers (including Payment Processors): Hosting, payments, analytics, communications, support, and security vendors, bound by confidentiality and data protection terms. Our payment processor handles payment credentials; Praedox does not store full card or bank details.

  • Business Transfers: In a merger, acquisition, financing, or sale of all/part of our business with appropriate protections.

  • Legal/Safety: To comply with law, legal process, enforce our terms, or protect rights, safety, and security.

  • At Your Direction: When you connect third parties or request sharing (e.g., support escalations, verification).

 

6) Data Retention

​

We keep information as long as necessary to provide the Services and for legitimate business, legal, and security purposes (e.g., tax/audit requirements, dispute resolution). Backup archives may persist for a limited period after deletion.

 

7) Your Choices

​

  • Account Details: Update your profile (including the email used during checkout) via your account or by contacting us.

  • Marketing: Opt out of marketing emails via the unsubscribe link or by contacting us. Transactional notices will still be sent.

  • Cookies: Manage via browser settings and our consent tools; some features may not work without certain cookies.

  • Do Not Track/GPC: We do not respond to DNT signals. Where required, we honor Global Privacy Control as an opt-out of “sale/share” for cross-context behavioral advertising, if applicable.

 

8) Your Privacy Rights

​

Depending on your location, you may have rights to:

  • Access/Portability: Request a copy of your personal information.

  • Correction: Request correction of inaccurate information.

  • Deletion: Request deletion, subject to legal exceptions.

  • Restrict/Object: Restrict or object to certain processing (e.g., direct marketing).

  • Opt-Out of Sale/Share/Targeted Ads: We do not sell personal information. If we “share” data as defined under CPRA/other laws, you may opt out via cookie preferences or by contacting us.

  • Withdraw Consent: Where processing is based on consent.

 

How to Exercise: Contact us from the email associated with your account (ideally the email used during checkout) at info@praedox.com or use the request form on our Privacy page. We will verify your request (e.g., email verification). Authorized agents may submit requests where permitted with proof of authority.

 

9) Regional Disclosures

​

9.1 California (CCPA/CPRA)

  • Categories: Identifiers (name, email, IP), commercial info (orders), internet activity (usage), geolocation (approximate), inferences (product interests), support communications.

  • Purposes: As described in Section 2.

  • Sharing/Sale: We do not sell personal information. We may “share” identifiers/internet activity with advertising/analytics partners to the extent regulated; you can opt out via cookie preferences or by contacting us.

  • Sensitive Personal Information: We do not seek to collect SPI; if collected incidentally, we use it only as necessary for the Services and security/compliance.

  • Non-Discrimination: We will not discriminate for exercising your rights.

  • Retention: See Section 6.

9.2 EEA/UK/Swiss (GDPR)

  • Controller: CIO Executive Advisors, LLC.

  • Legal Bases: Contract (to provide the Services, including payment through a processor); Legitimate Interests (security, improvement, analytics); Legal Obligation (compliance); Consent (marketing/advertising cookies where required).

  • Transfers: Personal data may be transferred to the U.S. and other countries; we use appropriate safeguards (e.g., Standard Contractual Clauses) where required.

  • Complaints: You may lodge a complaint with your supervisory authority; we encourage you to contact us first.

 

10) Security

​

We use reasonable administrative, technical, and physical safeguards to protect personal information. No method is 100% secure. You are responsible for safeguarding your credentials, API keys, and broker access details.

 

11) Children’s Privacy

​

The Services are not directed to children under 16 (or the age defined by local law). We do not knowingly collect personal information from children. If you believe a child has provided information, contact us to request deletion.

 

12) Third-Party Links and Services

​

Our Services may link to third-party sites/services (e.g., NinjaTrader, brokers, analytics providers). We are not responsible for their privacy practices. Review their policies before providing information.

 

13) Changes to This Policy

​

We may update this Policy from time to time. If we make material changes, we will post the updated Policy and update the “Last Updated” date. For significant changes, we may provide additional notice (e.g., banner or email). Your continued use after changes take effect indicates acceptance.

 

14) Contact Us

​

Risk Disclaimer

 

Trading comes with inherent risks due to the unpredictable nature of the market. It is important to understand that past performance is not necessarily indicative of future results; thus, investors must be aware that their investments could potentially lose value. CIO Executive Advisors, LLC Inc. (Praedox) does its best to ensure accuracy in its sources for fundamental and technical information provided on this site, however, it cannot be held responsible for any oversights made by those generating said data. Additionally, Futures; Options; Foreign Exchange; and Stock trading all come with a significant level of risk as these markets represent actual trading which carries additional uncertain aspects.

 

U.S. Government Required Disclaimer (Required by the Commodity Futures Trading Commission)

 

Futures and options trading is an actual trading opportunity that gives investors the potential to reap significant rewards, but with these large potential rewards comes large potential risks. In order for investors to succeed, they must gain an understanding of how markets function and be comfortable with the volatility associated with futures and options trading, such as sudden price movements, actual market conditions, liquidity, market structure and volatility. When engaging in such endeavors, only capital that one can truly afford to lose should be invested. Furthermore, investors should ensure they have sufficient risk capital available should they suffer losses within their trading account.

 

CFTC RULE 4.41.(b)(1)(i)

 

Simulated or hypothetical trading results have certain limitations, making them an unreliable predictor of future performance. Unlike results of actual trades executed in the market, simulated results do not accurately represent the possible impact of human error, lack of liquidity, and other market conditions. Additionally, the simulated results only take into account known variables, thus disregarding any unknown factors which may cause a differing result. As such, only risk capital should be used for simulated trading and past performance is not necessarily indicative of future performance.

View CFTC advisories as they contain more information on the risks associated with trading virtual currencies. 

bottom of page