Terms & Conditions

QUANT SAVVY – LICENSING FORM AND AGREEMENT

Prices are subject to change without notice, and all license fees are non-refundable.

Materials include the complete system signals/indicators for Multicharts/Tradestation files. The files are read-only with no open source and hence you can only modify specific inputs, e.g. contract size. (Multicharts/Tradestation is not required to license or to trade the systems, although it is highly recommended.) Depending on the option chosen by the client/subscribers, these materials will be installed on the client/subscribers VPS or sent to a 3rd party FCM/Broker upon receipt of this signed agreement & payment. To complete your licensing, please sign this electronic form and send it back to us.

If Quant Savvy deems a system performance has deteriorated, they can withdraw the system without notice to Client/subscriber. You can trade up-to 40 futures contracts per system (negotiated fee will be charged for every contract after 40), this will be charged for the month as soon as you trade live with increased position size. The subscription is not pro-rata, and the expiration date will align with the original expiration date of your first contract live traded.

The maintenance lease period is monthly. On the last trading day of your lease-period expiration, the client/subscriber will be sent, via email, the invoice for the monthly maintenance fee amount to be paid which will be calculated from the client/subscribers’ profit and loss statement.  It is at this point the client/subscriber indicate whether they will pay the maintenance fee and continue their subscription or discontinue and cancel.  The client/subscriber will have seven days to make the monthly maintenance fee payment, failure to do so will result in termination of the lease agreement and subscription.  At no point is the monthly maintenance fee deducted automatically from a client/subscribers account. Quant Savvy has no recurring payment methods employed; Quant Savvy has no access to client/subscriber accounts.

The initial start-up fee is non-refundable as soon as the system signals/indicators have been installed and set up correctly on the client/subscribers Virtual Private Server.  It is not even part refundable. You pay the total price for the lease selected. Quant Savvy will not automatically renew your lease nor does Quant Savvy have automated billing.

Once this signed form and the initial start-up fee have been received or authorized, your subscription term begins the next trading day or the date you choose below or place live trade. To make it easy we have created an online signature for this document.

To preserve the effectiveness of the systems, Quant Savvy reserves the right to limit the number of subscribers and to end subscriptions with a thirty-day notice before your subscription expiration.

To subscribe to the system(s) signals/indicators, please use the electronic signature feature and print a copy for yourself. Receipt of a signed copy is required before your subscription can be started.

Once payment is received, we may require your Multicharts UserID and Username or Tradestation Username and CustomerID (ignore if using 3rd Party Broker/Software Provider) to be sent via email or inputted into this electronic document. Please then select a start date if not the next trading day.

A Connection guide is also attached to the installation document but choosing and connecting to a Broker must be done with the help of Multicharts/Tradestation guides. Please make sure you choose a broker who is compatible with Multicharts/Tradestation software. If you are using Tradestation/3rd Party Broker/Software Provider, then the broker and software are all included.

LICENSING AGREEMENT

In licensing a Quant Savvy signal/indicator, I, the undersigned licensee, agree to hold confidential and in trust the proprietary information, trade secrets, trading methods, processes, formulae, compositions, and computer programs (“Information”) related to this trading system signals/indicators. I will not disclose any Information to any employee, associate, or broker except and only insofar as is necessary for the express purpose of trading for my personal account, and only with their agreement to execute and be bound by the terms of this agreement. If I plan to have my broker “auto-trade” my account and I, therefore, need to connect Multicharts/Tradestation signal with Broker as described in Multicharts/Tradestation technical documentation.

I understand that I have no obligation concerning any information known by me or generally known within the industry before the date of this agreement, or that becomes common knowledge within the industry hereafter. I agree that the signal/indicator will be used only to trade my personal account and funds. I understand that there are no refunds once the signal/indicator have been installed and setup on my compatible trading platform. I understand that any recommended portfolios are suggested combinations that are subject to change without notice, and that while Quant Savvy generally will attempt to inform me of portfolio changes, the ultimate choice and responsibility of a trading portfolio and its choice of components is mine alone. Quant Savvy is not responsible for missed or erroneous signals.

I understand and agree that any dispute arising out of connection to this agreement will be submitted to binding arbitration or non-binding mediation. I will bear my own expenses in connection with any such arbitration or non-binding mediation.

I understand and agree that this agreement shall be governed by, construed and enforced in accordance with the laws of the state and county of domicile of Quant Savvy. Any action or proceeding pursuant to this agreement shall be brought only within the county of domicile of Quant Savvy.

QUANT SAVVY IS CLASSIFIED AS A THIRD-PARTY SYSTEM DEVELOPER

Quant Savvy provides signal/indicator software based on a computerized system, all customers receive the same signals/indicators within any given subscription package. All advice is impersonal and not tailored to any specific individual’s unique situation.

Quant Savvy and all its principles/subsidiaries are registered company Quantari Group Limited which operates within the UK with no registered companies/businesses or offices in any other Country.

Quant Savvy and its principles are not required to register with the NFA as a CTA and are publicly claiming this exemption both via quantsavvy.com and lease agreement. Quant Savvy is not governed by any regulatory agencies. The information posted online or distributed through email has NOT been reviewed by any government agencies — this includes but is not limited to back-tested reports, statements and any other marketing materials. For more information on the exemption we are claiming, please visit the NFA website: http://www.nfa.futures.org/nfa-registration/cta/index.html.

CFTC EXEMPTION: RULE 4.41 AND RULES 4.14

Quant Savvy abides by CFTC RULE 4.41 and presents disclaimers clearly on quantsavvy.com (website) and lease agreement (electronically signed):

CFTC RULE 4.41 – Hypothetical or simulated performance results have certain limitations. Unlike an actual performance record, simulated results do not represent actual trading. Also, since the trades have not been executed, the results may have under-or over-compensated for the impact, if any, of certain market factors, such as lack of liquidity. Simulated trading programs, in general, are also subject to the fact that they are designed with the benefit of hindsight. No representation is being made that any account will or is likely to achieve profit or losses similar to those shown.

Quant Savvy is Exempt from CTA registration as CFTC rules 4.14 applies:

CFTC Rule 4.14(a)(9), which exempts from registration from an individual if it does not engage in any of these activities: (1) Directing client accounts; or (2) Providing commodity trading advice based on, or tailored to, the commodity interest or cash market positions or other circumstances or characteristics of clients.

OTHER EXEMPTIONS ALSO APPLICABLE

As quoted from the CFTC website, not all ‘commodity trading systems’ require registration, where commodity trading systems are defined as the following (and include FOREX):

  1. Computer programs that signal when to buy and sell commodity futures and options contracts
  2. Signals are based on mathematical formulas and are typically technical analyses of trading data, such as trading volume and prices
  3. Signals are not based upon fundamental analyses of economic factors, such as supply and demand

Technical analysis attempts to predict future price movements based on historical prices, price relationships and price trend.

NFA GUIDANCE: states that the following would be exempt from the need for NFA registration:

Exemptions: You make recommendations, such as advice to buy or sell specific futures contracts should a particular price level be reached, through newsletters, books and periodicals. The advice includes specific recommendations and the recipients of publications all receive the same advice. This exemption applies to Quant Savvy.  Quant Savvy does not advise to buy or sell specific futures contracts either via email or quantsavvy.com. Quant Savvy provides systems signals/indicators based on back-tests demonstrating hypothetical performance.

Exemptions: You conduct seminars at which you teach attendees how to trade commodity futures contracts aided by a software program that you sell and you invite seminar attendees to participate in a question-and-answer session at which you provide commodity trading advice without asking or receiving information about the personal characteristics of the attendees. Quant Savvy does not conduct seminars but if they did all advice would be impersonal.

 

NO ADVICE

All customers receive the same signals/indicators within any given package. All advice is impersonal and not tailored to any specific individual’s unique situation. Published percentage per month is based on back-tested results (see limitations on back-testing above) using our signals/indicators. This includes reasonable slippage and commission. This does NOT include fees we charge for licensing the signals/indicators which varies based on account size. Refer to our license agreement for full risk disclosure.  Quant Savvy does not make buy, sell or hold recommendations.  Quant Savvy abides by rules stated in Rule 4.14(a)(9).

The intent of Quant Savvy information supplied to a subscriber and represented on and through quantsavvy.com is for instructional, educational and entertainment purposes only.  This is neither a prospectus; nor an offer on our part with respect to the sale or purchase of any form of securities, intended or implied, and nothing contained herein is to be construed as a recommendation to take and or secure a position in any market at any time.  This is neither a solicitation nor an offer to buy/sell futures, but merely a representation of trade strategies. It is possible, at this date or some subsequent date, the subsidiaries, affiliates, creators, owners, officers, partners, directors, principals, shareholders, employees, web designer(s), moderators, or employees of Quant Savvy and its affiliates may buy, sell or own securities/future’s contracts, or buy, sell or own securities/futures’ contracts not mentioned by Quant Savvy.

 

NFA MEMBER AND FCM INTRODUCING BROKERS EXECUTED STRATEGIES

NFA Member firms who offer trade execution services for subscribers of Quant Savvy strategies and trade signals/indicators who use these computerized trading systems. Quant Savvy is third-party trading system developer (“third-party system developers”), who are neither NFA members nor registered with the CFTC due to exemptions. The NFA Member or FCM Broker must make their own agreement with their clients in these situations, typically the customer will execute a Letter of Direction that directs the Member to place trades for the customer in strict accordance with the signals/indicators generated by the trading system. In some cases, the Letter of Direction is more limited and includes instructions to follow only certain signals (e.g., signals in given contracts or signals that meet particular parameters). In almost all cases in which a Letter of Direction is used, the Member is not permitted to use any judgment when placing orders for the customer.

Quant Savvy does not direct client accounts. As defined by Commission Rule 4.10(f), “Direct, as used in the context of trading commodity interest accounts, refers to agreements whereby a person is authorized to cause transactions to be effected for a client’s commodity interest account without the client’s specific authorization.” Any agreement authorizing a person to direct a client’s account would be between executing firm/CTA/broker/FCM/introducing broker and Quant Savvy is not privy to this information nor plays any role in execution.

Quant Savvy takes no fee or profits from referring client/subscribers to use executing firm/CTA/broker/FCM/introducing broker. Quant Savvy receives no commissions or gains and no monetary value from referring client/subscribers to use executing firm/CTA/broker/FCM/introducing broker.

Quant Savvy is not required to be registered as a CTA, Quant Savvy is exempt and does not need to register as an IB. Quant Savvy can refer customers to an NFA Member but receives NO COMPENSATION FOR REFERRALS.

 

LICENSING AND SUBSCRIPTIONS

Per our disclaimer CFTC RULE 4.41, Quant Savvy is a third-party trading signal/indicator developer (not a registered CTA). Quant Savvy can and does change its subscription plan as any business to maximise utility and value. Quant Savvy can change its ongoing subscription plans at any time without warning.

Client/Subscribers have a lease agreement for Quant Savvy systems directly with Quant Savvy. Quant Savvy subscription is entirely separate from executing firm/CTA/broker/FCM/introducing broker/Software Provider and all subscriptions correspondence is directly between client/subscriber and Quant Savvy. Executing firm/CTA/broker/FCM/introducing broker/Software Provider is not privy to Quant Savvy subscription nor is compensated in any way.

Quant Savvy operates a monthly maintenance fee subscription plan which is considered a payment for the use of our signal/indicator software, this can hypothetically be calculated based on profits generated in a given month or a fixed fee. This fee is a maintenance fee for the upkeep of the software and costs for subscription including admin, technical, hardware, software, development related costs with Quant Savvy signal/indicator software. Maintenance fee is a model intended to give maximum benefit to clients/subscribers. The maintenance fee is calculated monthly and invoiced to clients/subscribers monthly. The Client/Subscribers indicate whether they will pay the maintenance fee and continue their subscription or discontinue and cancel, at no point is the fee deducted automatically from a Client/Subscribers account. The client/subscriber will have seven days to make the monthly maintenance fee payment, failure to do so will result in termination of the lease agreement and subscription.  Quant Savvy has no recurring payment methods employed; Quant Savvy has NO ACCESS to CLIENT/SUBSCRIBER ACCOUNTS. Quant Savvy cannot take any monies from Client/Subscribers automatically, only fees can be determined by correspondence directly with Client/Subscribers. Client/Subscribers indicate if they want to pay and continue or they can discontinue the subscription at any time without warning.

Quant Savvy has zero control over Client/Subscribers accounts, therefore, Client/Subscribers can discontinue their subscription at any time, Client/Subscribers can turn signal/indicators off at any time. Quant Savvy has no control over a client’s/subscriber’s level of risk or units/contracts they trade based on their subscription. Quant Savvy’s advice on risk levels and units/contracts traded is impersonal and only hypothetical computer-generated back-test reports indicate what may be required. At no point does Quant Savvy dictate a Client/Subscribers units or contracts to trade.

 

BY MEANS OF SERVER (VPS)

Electing to use the signals/indicators via a server to host your systems is at risk of the client/subscriber. Quant Savvy maintains only a software/hardware advisory role and will ensure the proper connection of software and ensure systems are running correctly. Quant Savvy does not at any time have control over your account nor actively investing your money for you at any time. Quant Savvy will ensure any access to client/subscriber hosted server will be monitored and only to ensure software/hardware is working correctly. Client/subscriber has full control and 24/7 login to the hosted desktop – client/subscriber is free to close or turn off the software at any time but doing so is at their own risk. If client/subscriber does choose to change software settings or turn systems off, they should inform Quant Savvy via email, phone or live help immediately.

Quant Savvy can only maintain proper software execution if they are informed fully of any client/subscriber intervention. Quant Savvy also asks client/subscribers using the Quant Savvy servers to preferably have a brokerage account connected to the software for the sole purpose of running Quant Savvy systems so that the monthly PnL can be calculated with ease.  Clients can actively discretionary trade via Quant Savvy servers, however, it is the client’s responsibility to log discretionary trades so that they are not included in the monthly PnL calculations.

Client/subscriber is responsible for logging into their respective broker so that Multicharts/Tradestation can connect and the automated systems can run. If the client/subscriber fails to log into their respective broker and run their relevant Multicharts/Tradestation software, then the client/subscriber is responsible if the signals/indicators have failed to run correctly. Quant Savvy bears no responsibility for client/subscriber failed logins.  Quant Savvy does NOT hold or have any access to client/subscriber login credentials.

The Client/subscriber can at any-time choose to stop using the server provided and choose to move their mode of operation. There is no contract to use the server provided or minimum term, the client/subscriber is free to cancel this service at any time and still maintain their Quant Savvy leased signal/indicators.

Quant Savvy maintains a position of software/hardware maintenance only and does not place trades or control brokerage account of the client/subscriber. Only the signal/indicators which clients can opt to run autonomously and leased to the client/subscriber can perform autonomous actions such as trades or generate signals/indicators. Quant Savvy technicians will load the subscribed portfolio of systems into Tradestation/Multicharts and set up the relevant charts and workspaces. Quant Savvy will then provide technical support should any issues arise. During futures contract rollover Quant Savvy technicians will perform this role on all charts traded by the subscribed portfolio. Please note it is up to the Client/subscriber to check that all charts, instruments, accounts traded, position/contract size traded and signals/indicators s traded is correct. Quant Savvy is not liable for any technician error as the duty is for the Client/subscriber to check all details/info is correct.

If Multicharts/Tradestation software or Broker error were to occur which is entirely outside of Quant Savvy control then Quant Savvy cannot be held liable for any missed trades as serious software error or broker connection issues (on the side of the broker) is out of control of Quant Savvy technicians.

Should server internet fail or software freeze or crash then Quant Savvy technicians may inform Client/subscribers of such issue, it is the responsibility of Client/subscriber to log into the platform and exit trades or continue systems if traded. Quant Savvy technicians can also provide technical support if issues arise but at no times is responsible for any profit or loss incurred by the client/subscriber due to said issues. Quant Savvy does not own any servers but uses 3rd party VPS server providers on a subscription basis.

Quant Savvy technicians will do the initial setup and then will only monitor the servers to ensure the software has not crashed or disconnected. Technicians will also apply hardware updates to the server. Client/subscribers can choose whether they want to live technical assistance with their server and are able to opt-out of this service.

 

THIRD-PARTY BROKER/SOFTWARE PROVIDER – SERVER AND SYSTEMS TRADE EXECUTION

Quant Savvy provides signals/indicators which are then sent to trade on 3rd Party Broker/Software Provider servers, and 3rd Party Broker/Software Provider execute trades. 3rd Party Broker/Software Provider is using Tradestation 9.1 or Tradestation 9.5 to run the software and Gain Capital or Tradestation or other compatible brokers are used to execute trades.

If a client/subscriber is subscribed to Quant Savvy systems and holds an account with 3rd Party Broker/Software Provider then Quant Savvy bears no liability regarding trade execution, trades made in error, the system fills and executions, data disconnection, data lag, missed ticks and data, incorrect data. Systems execution on 3rd Party Broker/Software Provider servers are out of the control of Quant Savvy who remains a party who merely supplied the signals/indicators and is treated as a third-party Referral Source. Beyond that, all liability of trading is a contract between 3rd Party Broker/Software Provider and the Client/subscriber. Quant Savvy will still have access and details regarding the Monthly Net Performance (all profit or loss is calculated on a single contract basis) if client/subscriber is willing to provide this. 3rd Party Broker/Software Provider has no authority to change Quant Savvy and Client/subscribers lease agreement. Quant Savvy still enforces its client/subscriber lease subscription regarding the maximum number of Futures contracts/Position Size a Client/subscriber has subscribed to trade. 3rd Party Broker/Software Provider has zero authority to extend client/subscribers lease period to trade Quant Savvy systems.

If 3rd Party Broker/Software Provider makes errors to either stop trading or keeps trading Client/subscribers systems even when the lease agreement between Quant Savvy and Client/subscriber has expired then 3rd Party Broker/Software Provider is liable for any performance during this period. Moreover, Quant Savvy can terminate Client/subscribers lease agreement should they not follow Quant Savvy lease agreement or fails to pay the monthly fee at the correct agreed time. 3rd Party Broker/Software Provider must abide by Quant Savvy lease agreements with the Client/subscriber and must enforce agreed lease expiry and start dates. 3rd Party Broker/Software Provider must also abide by Quant Savvy agreements with the Client/subscriber on maximum position/contract sizing based on a client/subscriber’s subscription, 3rd Party Broker/Software Provider has zero authority to select client/subscriber position size. 3rd Party Broker/Software Provider has no jurisdiction to continue trading Quant Savvy systems for Client/subscribers if Quant Savvy has terminated the lease agreement with the Client/subscriber.

If 3rd Party Broker/Software Provider fails to execute systems trades due to following reasons: fails to exit the trade at the correct time, fails to close trades at the correct time, incorrect position size, trades systems on the wrong market. Any software issues 3rd Party Broker/Software Provider has when attempting to execute Quant Savvy systems is entirely out of the control of Quant Savvy.

Client/subscriber cannot renew lease agreement of Quant Savvy systems directly with 3rd Party Broker/Software Provider – if this happens legal action will be taken immediately. Client/subscriber cannot negotiate Quant Savvy lease fee directly with 3rd Party Broker/Software Provider.

 

DRAWDOWN AND POTENTIAL LOSS EXAMPLES

Client/subscribers using Quant Savvy systems must recognise that drawdown is relative to initial account value. Quant Savvy only recommends minimum initial capital required to trade the portfolio of systems selected based on hypothetical back-test reports or historical data– this is entirely up to Client/subscriber to choose their own risk propensity and contract sizing per system. The same recommendation/advice is given to all potential and existing clients.

Client/subscribers must understand drawdown relative to the current market price.  Normalising a drawdown of example -$3500 per contract based on current market prices on 27th June 2017:

  • Using the ES market closing price 2358 this equates to -70 points ($50 per point) or -2.96% market range
  • Taking examples from 1900 ES market price (printed in 2014, 2015 and 2016) this same drawdown = -56 points or -$2800 or -2.96% market range
  • Taking examples from 1372 ES market price (printed in 2011, 2012 and 2013) this same drawdown = -40.5 points or -$2025 or -2.96% market range
  • Taking examples from 900 ES market price (printed in 2008 and 2009) this same drawdown = -26.5 points or -$1325 or -2.96% market range

Client/subscribers must consider that markets only work in percentages and do not care about dollar value. Quant Savvy indicates to get a clear idea of potential dollar drawdown value it is best to normalise the dollar drawdown based on current market prices. Market prices can rise quickly, and this will have a significant impact on dollar drawdown. Client/subscriber must understand that past hypothetical drawdown returns can never give an accurate picture of potential drawdown unless drawdown is normalised to current market price.

 

RISK MANAGEMENT

Please be aware that we offer only signals/indicators, we do not adjust your position size or number of units you are trading. It is entirely the client/subscriber’s duty and due diligence to trade an appropriate number of contract/units per system. We do not have any control over your account as Client/subscriber is using their own brokerage account – we can simply offer the same education and guidance to all clients/subscribers based on historical performance examples – advice is not tailored to a specific client/subscriber.

Client/subscribers can adjust their position/unit/contract size at any time and should actively monitor their potential risk on each trade. The signals/indicators will only have stops and targets but cannot control overall exposure or excessive risk-taking due to client/subscriber trading excessive position/unit/contract size.

If our software is being used by a 3rd party broker FCM then understand that each client/subscriber must individually select their own position/unit/contract size per system. Client/subscribers who take excessive risk do so at their own peril, at Quant Savvy we have no method or means to change a client/subscriber position/unit/contract size. No indicator or strategy will automatically change the position/unit/contract size before entering a trade – we provide a signal/indicator solely and do not provide not any risk management for adjusting position/unit/contract size, this must all be done manually by the client/subscriber or 3rd party broker.

Example: an indicator has generated a signal for a trade, the indicator can only trade the number of position/unit/contracts the client/subscriber themselves has selected (they can adjust this at any time) – the indicator does not adjust the position/unit/contract size and the number of position/unit/contract being traded automatically – the indicator does not track the client/subscribers account liquidity or balance and will simply provide the signal to all client/subscribers. All risk management in terms of position/unit/contract to trade is the client/subscriber’s responsibility.

 

RETURNS POLICY

If you purchase a subscription to Quant Savvy software and have paid for purchase but then decide not to get a Multicharts/Tradestation UserID or Username, or you wish to cancel your order, you can receive a full refund if we have not purchased and set up your server. If we have installed the system signals/indicators to your server, Quant Savvy has a sunk cost and refunds can only be provided if the software has not been installed.

Regardless of contract type all purchases/subscriptions are non-refundable after the signal/indicator software has been sent by Quant Savvy and received by the client/subscriber.

Please email info@quantsavvy.com for returns as soon as possible and before we send you the signals/indicators software.

As soon as a live trade is placed there are no refunds whatsoever, this means if a client/subscriber subscribes to trade more position/unit/contracts than they traded there would not be a refund on the remaining position/unit/contracts not traded.

 

PLEASE READ THE DISCLOSURES & DISCLAIMERS AND AGREEMENT AND SIGN & DATE THE ELECTRONIC FORM BELOW DISCLOSURES & DISCLAIMERS

Commodity trading bears a high degree of risk. People can and do lose money. Past performance does not guarantee future results. Although every attempt is made to ensure the accuracy of these numbers, we cannot guarantee that they are, due to inaccuracies in data or errors in calculation.

HYPOTHETICAL PERFORMANCE RESULTS HAVE MANY INHERENT LIMITATIONS, SOME OF WHICH ARE DESCRIBED BELOW. NO REPRESENTATION IS BEING MADE THAT ANY ACCOUNT WILL OR IS LIKELY TO ACHIEVE PROFITS OR LOSSES SIMILAR TO THOSE SHOWN.  IN FACT THERE ARE FREQUENTLY SHARP DIFFERENCES BETWEEN HYPOTHETICAL PERFORMANCE RESULTS AND THE ACTUAL RESULTS SUBSEQUENTLY ACHIEVED BY ANY PARTICULAR TRADING PROGRAM. ONE OF THE LIMITATIONS OF HYPOTHETICAL PERFORMANCE RESULTS IS THAT THEY ARE GENERALLY PREPARED WITH THE BENEFIT OF HINDSIGHT. IN ADDITION, HYPOTHETICAL PERFORMANCE TRADING DOES NOT INVOLVE FINANCIAL RISK, AND NO HYPOTHETICAL TRADING RECORD CAN COMPLETELY ACCOUNT FOR THE IMPACT OF FINANCIAL RISK IN ACTUAL TRADING. FOR EXAMPLE, THE ABILITY TO WITHSTAND LOSSES OR TO ADHERE TO A PARTICULAR TRADING PROGRAM IN SPITE OF TRADING LOSSES ARE MATERIAL POINTS WHICH CAN ALSO ADVERSELY AFFECT ACTUAL TRADING RESULTS. THERE ARE NUMEROUS OTHER FACTORS RELATED TO THE MARKETS IN GENERAL OF THE IMPLEMENTATION OF ANY SPECIFIC TRADING PROGRAM WHICH CANNOT BE FULLY ACCOUNTED FOR IN THE PREPARATION OF HYPOTHETICAL PERFORMANCE RESULTS AND ALL OF WHICH CAN ADVERSELY AFFECT ACTUAL TRADING RESULTS.

Nothing presented here or on the Quant Savvy web site should be construed as a recommendation to buy or sell any security. Trading in Commodity Futures is very risky. There is a possibility of substantial financial loss, greater even than monies initially invested. The simulated, hypothetical performance results presented herein have certain inherent limitations, due to the fact that the trades have not actually been executed. Simulated trading results, in general, may be influenced by the fact that the algorithms which generated them were designed in consideration of historical trends, and with the benefit of hindsight. The past real or hypothetical performance of any of the Quant Savvy systems is not a guarantee of future results, real or hypothetical. No representation is made that any trading account would or would be likely to achieve profits or losses similar to the real or hypothetical results described herein. Quant Savvy Systems, including but not limited to all agents & affiliates of Quant Savvy, participating in the distribution of the information contained in, & operation of, the web sites known as “www.QuantSavvy.com,” www. QuantSavvy.co.uk, and, are held harmless and are without liability regarding any use whatsoever of the information presented on this web site. For the purposes of this site, “real-time” means trades and results that are out-of-sample, i.e. they occurred based upon the system rules in place at that time. “Real-time” does not necessarily refer to actual trades taken.

Trading may not be suitable for all viewers of this site or potential users of Quant Savvy. You, and not Quant Savvy, assume the entire cost and risks of any trading you choose to undertake. Under no circumstances shall Quant Savvy be liable for any special or consequential damages that result from the use of or the inability to use, the materials, if any, provided by Quant Savvy. Applicable law may not allow the limitation or exclusion of liability or incidental or consequential damages, so the above limitation or exclusion may not apply to you. In no event shall Quant Savvy total liability to you or your assigns for all damages, losses and causes of action, whether contract or tort (including, but not limited to negligence), or otherwise exceed the amount paid by you, if any, for use of materials provided by Quant Savvy.

The information, data, and methodologies contained in this site and available for purchase or lease (the Information) are not intended to be published or made available to any person in any jurisdiction where doing so would result in contravention of any applicable laws or regulations. Accordingly, if it is prohibited to make such information available in your jurisdiction or to you (by reason of your nationality, residence or otherwise) it is not directed at you.

Before reviewing the pages of our site or making a purchase or lease, you must be satisfied that doing so will not result in such a contravention and is not so prohibited, and by proceeding to review them you will be confirming that this is not the case.

Quant Savvy has taken all reasonable care and precaution to ensure that the information is fair and accurate or has been compiled from sources believed to be reliable. Nevertheless, Quant Savvy does not make any representations or warranty, express or implied, as to the accuracy, completeness, or fitness for any purpose or use of the Information. The Information may not in all cases be current, and it is subject to continuous change. Accordingly, you should not rely on any of the Information as authoritative or a substitute for the exercise of your own skill and judgment in making any investment or other decision. Quant Savvy does not warrant that the information is error-free, and will not be liable for any direct, indirect, or consequential loss arising from any use of or reliance on this information. QUANT SAVVY IS NOT A REGISTERED BROKER-DEALER OR FINANCIAL ADVISOR. QUANT SAVVY DOES NOT PROVIDE PERSONAL INVESTMENT ADVICE.

Any portfolios recommended by Quant Savvy are suggested combinations that are subject to change without notice. The ultimate choice and responsibility of a trading portfolio is the client/subscriber’s alone. Any results or performance numbers are hypothetical, apply only to the current recommended portfolios and systems, and are not intended to show the results of past recommended portfolios or systems. Quant Savvy is not responsible for notifying client/subscribers about changes in portfolios or systems and has neither the right nor responsibility to alter what is traded in client/subscriber accounts.

Unless otherwise stated, hypothetical results reported by Quant Savvy are those generated by the latest version of the systems, including the specific rules and parameter settings. It is therefore not advisable, nor is it the intended purpose, to use these hypothetical results as a guide to what past results should have been achieved by utilizing the version of the systems in effect at a past time.

Quant Savvy makes a good faith effort to see that all trading signals/indicators s are correctly executed but cannot be held liable for missed or erroneous trades or for an inability or lack of monitoring of client/subscriber accounts. No representation is being made that any account will achieve similar results to any other account or actual or hypothetical performance numbers presented in the Quant Savvy site or materials. Results can vary significantly from brokerage to brokerage, depending upon many factors not under the control of Quant Savvy.

In some cases, slightly different entry and exit times and prices may be used in leased and/or purchased copies of the trading systems, in an attempt to lessen the impact of multiple orders reaching the market at or close to the same time. While over time and an extended number of trades these differences have in the past tended to be small and immaterial, they may, in fact, prove to have a material impact or over shorter timeframes have a material impact.

Quant Savvy provides signals and indicators based on a computerized system. All customers receive the same signals/indicators within any given package. All advice is impersonal and not tailored to any specific individual’s unique situation. Quant Savvy and its principles are not required to register with the NFA as a CTA and are publicly claiming this exemption. Quant Savvy is not governed by any regulatory agencies. The information posted online or distributed through email has NOT been reviewed by any government agencies — this includes but is not limited to back-tested reports, statements and any other marketing materials. Carefully consider this prior to purchasing our signals/indicators. For more information on the exemption we are claiming, please visit the NFA website: http://www.nfa.futures.org/nfa-registration/cta/index.html. If you are in need of professional advice unique to your situation, please consult with a licensed broker/CTA. U.S. GOVERNMENT REQUIRED DISCLAIMER: Commodity Futures Trading Commission Futures trading has large potential rewards, but also large potential risk. You must be aware of the risks and be willing to accept them in order to invest in the futures and stock markets. Don’t trade with money you can’t afford to lose. This is neither a solicitation nor an offer to Buy/Sell futures. No representation is being made that any account will or is likely to achieve profits or losses similar to those discussed on this website or on any reports. The past performance of any trading system or methodology is not necessarily indicative of future results. With the exception of the statements posted from live accounts on Tradestation and/or Gain Capital, all results, graphs and claims made on this website and in any video blogs and/or newsletter emails are from the result of back-testing our systems during the dates indicated. These results are not from live accounts trading our systems. They are from simulated accounts which have limitations (see CFTC RULE 4.41 below). Actual results do vary given that simulated results could under — or overcompensate the impact of certain market factors. Furthermore, our systems use back-testing to generate trade lists and reports which does have the benefit of hindsight. While back-tested results might have spectacular returns, once slippage, commission and licensing fees are taken into account, actual returns will vary. Posted maximum drawdowns are measured on a closing month to closing month basis. Furthermore, they are based on back-tested data (refer to limitations of back-testing below). Actual drawdowns could exceed these levels when traded on live accounts. CFTC RULE 4.41 – Hypothetical or simulated performance results have certain limitations. Unlike an actual performance record, simulated results do not represent actual trading. Also, since the trades have not been executed, the results may have under-or over-compensated for the impact, if any, of certain market factors, such as lack of liquidity. Simulated trading programs, in general, are also subject to the fact that they are designed with the benefit of hindsight. No representation is being made that any account will or is likely to achieve profit or losses similar to those shown. Statements posted from our actual customers trading the systems include slippage and commission (Customers A, B, C, D, E and F). Statements posted are not fully audited or verified and should be considered as customer testimonials. Individual results do vary. They are real statements from real people trading our systems autonomously and as far as we know, do NOT include any discretionary trades. Trade lists posted on this site also include slippage and commission. This strictly is for demonstration purposes. Quant Savvy does not make buy, sell or hold recommendations. Unique experiences and past performances do not guarantee future results. You should speak with your CPA or financial representative, broker-dealer, or financial analyst to ensure that the software/strategy that you utilize is suitable for your investment profile before trading in a live brokerage account. All advice and/or suggestions given here are intended for running automated software in simulation mode only. Trading futures is not for everyone and does carry a high level of risk. Quant Savvy nor any of its principles, is NOT registered as an investment advisor. All advice given is impersonal and not tailored to any specific individual. Published percentage per month is based on back-tested results (see limitations on back-testing above) using our systems. This includes reasonable slippage and commission. This does NOT include fees we charge for licensing the systems which vary based on account size. Refer to our license agreement for full risk disclosure.

We reserve the right to:

  • modify or withdraw, temporarily or permanently, this Website (or any part thereof) with or without notice to you and you confirm that we shall not be liable to you or any third party for any modification to or withdrawal of the Website; and/or
  • change the Conditions from time to time, and your continued use of the Website (or any part thereof) following such change shall be deemed to be your acceptance of such change. It is your responsibility to check regularly to determine whether the Conditions have been changed. If you do not agree to any change to the Conditions then you must immediately stop using the Website.

While we will use reasonable endeavours to verify the accuracy of any information we place on the Website, we make no warranties, whether express or implied in relation to its accuracy. The intent of Quant Savvy information supplied to a subscriber and represented on and through quantsavvy.com is for instructional, educational and entertainment purposes only.  This is neither a prospectus; nor an offer on our part with respect to the sale or purchase of any form of securities, intended or implied, and nothing contained herein is to be construed as a recommendation to take and or secure a position in any market at any time.  This is neither a solicitation nor an offer to buy/sell futures, but merely a representation of trade strategies. It is possible, at this date or some subsequent date, the subsidiaries, affiliates, creators, owners, officers, partners, directors, principals, shareholders, employees, web designer(s), moderators, or employees of Quant Savvy and its affiliates may buy, sell or own securities/future’s contracts, or buy, sell or own securities/futures’ contracts not mentioned by Quant Savvy.  Additionally, subsidiaries, affiliates, creators, owners, officers, partners, directors, principals, shareholders, employees, web designer(s), moderators, or employees of Quant Savvy may or may not have positions or effect transactions in the futures, securities or commodities mentioned or described, and may also employ trading strategies that may be consistent or inconsistent with the strategies described on the web site, in the educational series, or in the chat room.  You agree to indemnify and hold harmless from any claim or demand, including reasonable attorneys’ fees, any and all subsidiaries, affiliates, creators, owners, officers, partners, directors, principals, shareholders, employees, web designer(s), moderators, or employees of Technical Traders.  You further agree Quant Savvy shall not be liable for any direct, indirect, incidental, special or consequential damages arising out of the use of any of the content, materials, information, or data derived from Quant Savvy, quantsavvy.com or any of its subsidiaries, affiliates, creators, owners, officers, partners, directors, principals, shareholders, employees, web designer(s), moderators, or employees.

 

The materials, data or information contained herein is provided and has been obtained from sources believed to be reliable but is provided as “AS IS” and on an “AS-AVAILABLE” basis with no warranties of any kind and are not guaranteed as to their accuracy or completeness.  Quant Savvy does not warrant the accuracy or completeness of the materials, data or information and expressly disclaims any warranties or fitness for a particular purpose.  Quant Savvy will not be responsible for any loss or damage that could result from any material, data or information made available to you via this web site.  Please check market fundamentals and technical conditions before considering these or any trades.  In no uncertain terms should the content of this website be construed as an express or implied promise, guarantee or implication by or from Quant Savvy, Quant Savvy.com or any of its subsidiaries, affiliates, creators, owners, officers, partners, directors, principals, shareholders, employees, web designer(s), moderators, or employees that you will profit or your losses can or will be limited in any way.  All trading involves high risk; past performance and/or results of any trading system or methodology are not necessarily indicative of future performance and/or results.

 

AGREEMENT

By leasing a Quant Savvy system signal/indicator, I, the undersigned, hereby acknowledge that I have read, that I understand, and that I accept the statements, terms and conditions presented in the lease form and agreement text on this page and on the previous page. I am leasing the system signal/indicator exclusively for my own use in trading my personal funds and will not use the systems to trade the accounts of other parties or allow other accounts to trade the signals/indicators. I agree that I will utilise the system signal/indicator entirely at my own risk and that I will be solely responsible for any losses that may be incurred. I understand that the leasing of the system signal/indicator includes no guarantee of accuracy or future profitability. I have been informed about the risks of relying on hypothetical performance and I am aware that any form of past performance is not necessarily indicative of future results. I understand and agree that any dispute arising out of connected to this agreement will be submitted to binding arbitration or non-binding mediation. I will bear my own expenses in connection with any such arbitration or non-binding mediation. In no event will Quant Savvy or its owners or employees be held liable for any costs or damages or losses, direct or indirect, beyond the amount of lease fees paid by me.

I understand and agree that this agreement shall be governed by, construed and enforced in accordance with the laws of United Kingdom or the current state of domicile for Quant Savvy. Any action or proceeding pursuant to this agreement shall be brought only within United Kingdom or the current county of domicile for Quant Savvy.

Please read the following statements carefully and tick the boxes before signing;

I understand I am purchasing a product from Quant Savvy which consists of a subscription to the Quant Savvy trading systems signal/indicator software package.

I understand that it is my decision alone whether to use the Quant Savvy autonomous trading systems signals/indicators to place live/sim trades or follow signals/indicators in my own brokerage account and I have the freedom to stop using these systems at any time if I choose to do so.

I understand that there are no refunds once the server has been set up and system signals/indicators have been installed and set up on my compatible trading platform. Once installed Quant Savvy has a sunk cost, refunds can only be provided if the server has not been setup.

I have read, understood and agree to the terms and conditions of the Quant Savvy Licensing Form and Agreement

INTRODUCTION

Welcome to the Quant Savvy privacy notice. Quant Savvy respects your privacy and is committed to protecting your personal data. This privacy notice will inform you as to when and why we collect personal information about people who visit our website (regardless of where you visit from), how we use it, the conditions under which we may disclose it to others, how we keep it secure and tell you about your privacy rights and how the law protects you. We may update this policy on occasion so please do check to ensure you are happy with any changes. By using our website, and by the provision of information to us you will constitute acknowledgment of the terms of this privacy policy. Please do not send us any of your information if you do not want it to be used in the ways described in this privacy policy. Please also use the Glossary to understand the meaning of some of the terms used in this privacy notice.

1. IMPORTANT INFORMATION AND WHO WE ARE
2. THE DATA WE COLLECT ABOUT YOU
3. HOW IS YOUR PERSONAL DATA COLLECTED
4. HOW WE USE YOUR PERSONAL DATA
5. DISCLOSURES OF YOUR PERSONAL DATA
6. INTERNATIONAL TRANSFERS
7. DATA SECURITY
8. DATA RETENTION
9. YOUR LEGAL RIGHTS
10. GLOSSARY

1. Important information and who we are

Purpose of this privacy notice:

This privacy notice aims to give you information on how Quant Savvy collects and processes your personal data through your use of this website, including any data you may provide through this website when you sign up to our newsletter, purchase a product or service, or take part in a competition. This website is not intended for children. It is important that you read this privacy notice together with any other privacy notice or fair processing notice we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This privacy notice supplements the other notices and is not intended to override them.

Controller:
Quant Savvy is the data controller and responsible for any personal information provided to us when you use our services (collectively referred to as ” Quant Savvy”, “we”, “us” or “our” in this privacy notice).

We have appointed a data protection officer (DPO) who is responsible for overseeing questions in relation to this privacy notice. If you have any questions about this privacy notice, including any requests to exercise your legal rights (as specified in section 9 below), please contact the DPO using the details set out below.

Contact details:
Email address: support@quantsavvy.com
Postal address: The Techno Centre, Coventry University Technology Park, United Kingdom, CV1 2TT
Telephone number: US/Canada Toll Free: 1-888-414-0759 Rest of World: +44(0) 7424-811-346

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance. Changes to the privacy notice and your duty to inform us of changes. This version was last updated in May 2018. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.

Third-party links:
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy notice of every website you visit.

2. The data we collect about you

Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of personal data about you which we have grouped together follows:

Identity Data includes first name, maiden name, last name, username or similar identifier, marital status, title, date of birth and gender.

Contact Data includes billing address, delivery address, email address and telephone numbers.

Financial Data includes bank account and payment card details.

Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.

Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website.

Profile Data includes your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses.

Usage Data includes information about how you use our website, products and services.

Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data may be derived from your personal data but is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this privacy notice. We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health and genetic and biometric data). Nor do we collect any information about criminal convictions and offences. If you fail to provide personal data where we need to collect personal data by law, or under the terms of a contract we have with you and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with goods or services). In this case, we may have to cancel a product or service you have with us but we will notify you if this is the case at the time.

3. How is your personal data collected?

We use different methods to collect data from and about you including through:

Direct interactions. You may give us your Identity, Contact, Technical and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

(a) apply for our products or services;

(b) create an account on our website or utilise the live chat function on our website;

(c) subscribe to our service or publications;

(d) request marketing to be sent to you;

(e) make a telephone call to us and leave a message or request a call back;

(f) enter a competition, promotion or survey;

(g) react to marketing posts on our social media forums (including but not limited to our Facebook, Twitter, Instagram pages); or

(h) give us some feedback.

Automated technologies or interactions. As you interact with our website, we may automatically collect Technical Data about your equipment, browsing actions and patterns. We collect this personal data by using cookies, server logs and other similar technologies. We may also receive Technical Data about you if you visit other websites employing our cookies. Please see our cookie policy at the bottom of this page for further details.

Third parties or publicly available sources. We may receive personal data about you from various third parties as set out below:

Technical Data, Profile Data, Usage Data, Marketing and Communication Data, and Aggregated Data from the following parties:

(a) analytics providers such as Google based outside the EU;

(b) advertising networks;

(c) search information providers;

(d) third party providers of technical, payment and delivery services;

(e) third party data brokers; and

(f) from publicly available sources.

4. How we use your personal data

We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.

Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

Where we need to comply with a legal or regulatory obligation.

Where we have your consent to do so.

Purposes for which we will use your personal data:

We have set out below, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please see paragraph 10 if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out below.

We use your information to:

– Register you as a new customer

o Legal Basis (a) Necessary for our legitimate interests

– Process and deliver your order including:

o To manage payments, fees and charges

o To collect and recover money owed to us

– Legal Bases (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to recover debts due to us)

– Manage our relationship with you which will include:

o Notifying you about changes to our terms or privacy policy

o Asking you to leave a review or take a survey

– Legal Bases (a) Performance of a contract with you; (b) Necessary to comply with a legal obligation; (c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our products/services)

– Enable you to partake in a prize draw, competition or complete a survey

o Legal Bases (a) Performance of a contract with you; (b) Necessary for our legitimate interests (to study how customers use our products/ services, to develop them and grow our business)

– Administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

o Legal Bases (a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise); (b) Necessary to comply with a legal obligation

– Deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

o Legal Basis (a) Necessary for our legitimate interests (to study how customers use our products/ services, to develop them, to grow our business and to inform our marketing strategy)

– Use data analytics to improve our website, products/ services, marketing, customer relationships and experiences

o Legal Basis (a) Necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and inform our marketing strategy)

– Make suggestions and recommendations to you about goods or services that may be of interest to you

o Legal Basis (a) Necessary for our legitimate interests (to develop our products/ services and grow our business)

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We have established the following personal data control mechanisms:

1. Promotional offers from us

We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you (we call this marketing).

You will receive marketing communications from us if you have requested information from us or purchased goods or services from us or if you provided us with your details when you entered a competition or registered for a promotion and, in each case, you have not opted out of receiving that marketing.

2. Third-party marketing

We will get your express opt-in consent before we share your personal data with any company outside of Quant Savvy for marketing purposes.

3. Opting out

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you via email or SMS. Alternatively, you can contact us via customer services and we can manually unsubscribe you from our mailing/marketing lists.

Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, product/service experience or other transactions.

4. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see cookies policy at the bottom of this page.

5. Change of purpose

We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our DPO.

If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

5. Disclosures of your personal data

We may have to share your personal data with third parties for the purposes described in paragraph 4 above.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions.

6. International transfers

In order to provide you with our services and products, we may need to transfer your personal information to locations outside the European Economic Area (EEA).

Some of our external third parties (for example Facebook, Google, Amazon) are based outside the European Economic Area (EEA) so their processing of your personal data will involve a transfer of data outside the EEA.

Whenever we transfer your personal data out of the EEA, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is implemented:

We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data by the European Commission. For further details, see European Commission: Adequacy of the protection of personal data in non-EU countries.

Where we use certain service providers, we may use specific contracts approved by the European Commission which give personal data the same protection it has in Europe. For further details, see European Commission: Model contracts for the transfer of personal data to third countries.

Where we use providers based in the US, we may transfer data to them if they are part of the Privacy Shield which requires them to provide similar protection to personal data shared between the Europe and the US. For further details, see European Commission: EU-US Privacy Shield.