Privacy Policy

PIONEER ADVISORY, LLC

a Delaware limited liability company

Last modified: 10.02.2026

Acceptance of Privacy Policy

Pioneer Advisory, LLC, a Delaware limited liability company ("Pioneer Advisory," "Company," "we," or "us"), respects your privacy and is committed to protecting it through our compliance with this Privacy Policy ("Privacy Policy" or "Policy").

This Policy describes the types of information Pioneer Advisory may collect from you, receive from your broker, such as Interactive Brokers LLC, a FINRA-registered broker-dealer and member of SIPC, or that you may provide when you visit PiTrade ("PiTrade" or "mobile application") and our practices for collecting, using, maintaining, protecting, and disclosing that information.

All definitions referenced within this Policy shall be interpreted in accordance with the definitions provided in the Terms of Service at https://support.pitrade.com/disclosures/terms-and-conditions, unless otherwise expressly provided. In the event of any discrepancy or ambiguity between the definitions outlined in this Policy and those articulated in the Terms of Service, the definitions set forth in the Terms of Service shall prevail.

This Policy applies to information Pioneer Advisory collects:

  • Through PiTrade.
  • In email, text, and other electronic messages you send to the Company.
  • From Interactive Brokers LLC when you use the Interactive Brokers LLC brokerage services.
  • When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this Policy.

This Policy does not apply to information collected by:

  • Us offline or through any other means, including on any other website operated by us or any third party (including our affiliates and subsidiaries); or
  • Any third party (including our affiliates and subsidiaries), including through any application or content (including advertising) that may link to or be accessible from or through PiTrade.

Please read this Policy carefully to understand our policies and practices regarding your information and how Pioneer Advisory will treat it. If you do not agree with our policies and practices, your choice is not to use our mobile application. By accessing or using PiTrade, you agree to this Privacy Policy. This Policy may change from time to time. Your continued use of PiTrade after Pioneer Advisory makes changes is deemed to be acceptance of those changes, so please check the Policy periodically for updates.

Territoriality

Regardless of where our servers are located, your personal data may be processed by us in the United States, where data protection and privacy regulations may or may not provide the same level of protection as in other parts of the world.

BY USING PItRADE, YOU UNEQUIVOCALLY AND UNAMBIGUOUSLY CONSENT TO THE COLLECTION AND PROCESSING IN THE UNITED STATES OF ANY INFORMATION COLLECTED OR OBTAINED BY US THROUGH VOLUNTARY SUBMISSIONS, AND, TO THE EXTENT POSSIBLE, THAT U.S. LAW SHALL GOVERN ANY SUCH COLLECTION AND PROCESSING.

This Privacy Policy is subject to California Consumer Privacy Act of 2018, as amended, ("CCPA"), and other applicable privacy laws. Pioneer Advisory agrees that under CCPA, we are a "Service Service Provider" or a "Business", and you, if you are an individual residing in California, a "Consumer" with certain protected privacy rights concerning your "Personal Information". We will take commercially reasonable steps to maintain compliance with CCPA requirements.

Children Under the Age of 18

Our mobile application is not intended for people under 18 years of age. No one under age 18 may provide any information to or on PiTrade. Pioneer Advisory does not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on PiTrade or through any of its features, register on PiTrade, make any securities operations through PiTrade, use any of the interactive features of PiTrade, communicate or arrange with other users, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If Pioneer Advisory learns it has collected or received personal information from a child under 18 without verification of parental consent, Pioneer Advisory will delete that information. If you believe Pioneer Advisory might have any information from or about a child under 18, please contact us at support@pitrade.com.

Residents of certain states under 13, 16, or 18 years of age may have additional rights regarding the collection and sale of their personal information.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our mobile application, including information:

  • By which you may be personally identified, such as name, postal address, email address, telephone number, date of birth, or any other identifier by which you may be contacted online or offline and personal information of individuals associated with you, such as trustees, representatives, investors, clients, beneficial owners, or agents ("personal information");
  • Information classified as personal or protected by state or federal law, including nationality, place, and date of birth;
  • Commercial information, including tax information, bank account details, source of funds details, and investment activity-related information;
  • Internet or electronic network activity information, including browsing history, search history, and interaction with websites, applications, or advertisements;
  • Professional or employment-related information, including your employment, employer's name, and income;
  • Inferences drawn from your personal information to create a profile reflecting your preferences; and
  • Your investment experience and investing history, investment plans, portfolios.

We collect this information:

  • Directly from you when you provide it to us;
  • From public sources, such as public records and the Internet;
  • From third parties, for example, our business partners or your brokers, such as Interactive Brokers LLC;
  • Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and/or web beacons.

Information You Provide to Us

The information Pioneer Advisory collects on or through our mobile application may include:

  • Information that you provide by filling in forms on our mobile application. This includes information provided at the time of setting up your investor profile, creating investment strategies, or requesting further services. Pioneer Advisory may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our mobile application;
  • Records and copies of your correspondence (including email addresses), if you contact us;
  • Your responses to surveys that Pioneer Advisory might ask you to complete for research purposes;
  • Details of transactions you carry out through our mobile application and of the fulfillment of your orders. You may be required to provide financial information before placing an order through our mobile application.

You also may provide information to be published or displayed (hereinafter, "posted") on public areas of PiTrade, or transmitted to other users of PiTrade or third parties, this includes your investment strategies and portfolios and your profile information (collectively, "User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Please be aware that no security measures are perfect or impenetrable. Additionally, Pioneer Advisory cannot control the actions of other users of PiTrade with whom you may choose to share your User Contributions. Therefore, Pioneer Advisory cannot and does not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our mobile application, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Usage Details. When you access and use PiTrade, we may automatically collect certain details of your access to and use of the mobile application, including traffic data, location data, logs, and other communication data and the resources that you access and use on or through PiTrade;
  • Device Information. We may collect information about your mobile device and internet connection, including the device's unique device identifier, IP address, operating system, browser type, mobile network information, and the device's telephone number;
  • Location Information. PiTrade does not collect real-time information about the location of your device.

The information we collect automatically is only statistical data and does not include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our mobile application and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our mobile application according to your individual interests.
  • Speed up your searches.
  • Recognize you when you return to our mobile application.

If you do not want us to collect this information do not download PiTrade or delete it from your device. We also may use these technologies to collect information about your activities over time and across third-party websites, apps, or other online services (behavioral tracking).

The technologies we use for this automatic data collection may include:

  • Cookies (or mobile cookies). A cookie is a small file placed on your smartphone. It may be possible to refuse to accept mobile cookies by activating the appropriate setting on your smartphone. However, if you select this setting you may be unable to access certain parts of PiTrade.
  • Web Beacons. Pages of PiTrade and our emails]may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related app statistics (for example, recording the popularity of certain app content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie non-personal information collected automatically to personal information about you that we collect from other sources or that you provide to us.

Third-Party Information Collection

When you use PiTrade or its content, certain third parties may use automatic information collection technologies to collect information about you or your device. These third parties may include:

  • Third-party brokers;
  • Advertisers, ad networks, and ad servers;
  • Analytics companies;
  • Your mobile device manufacturer;
  • Your mobile service provider.

These third parties may use tracking technologies to collect information about you when you use this mobile application. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different websites, apps, and other online services websites. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.

Exercising Your Rights

We will acknowledge receipt of your request to exercise your privacy rights emailed at support@pitrade.com within 10 business days of receiving it, and will do our very best to respond within 30 calendar days of receipt of your request. If we are unable to provide our response within 30 days, we shall notify you as soon as we become aware of the possible delay and provide an explanation of why additional time is needed to respond. Additional time for response may not exceed 45 days.

Before we respond to any requests relating to your personal information, we may take steps to reasonably verify the identity of the person making the request ("Requestor") to make sure it's you, or your authorized agent. We do this to avoid disclosing your information to third parties and bad actors, not to inconvenience you in any way. The more sensitive the information subject to the request, the more rigorous the verification may be. If the identity of the Requestor cannot be reasonably verified, either as the consumer or their agent, then in order to protect that consumer, we shall not disclose the personal information requested.

Our response to your request shall be free of charge, up to twice annually per consumer, unless the request is unfounded, excessive, or repetitive, in which case you may be charged a reasonable administrative cost.

If we decline your request, we will provide you with notice of that decision, including a justification for the declination.

Third-Party Use of Cookies and Other Tracking Technologies

Some content or applications, including advertisements, on PiTrade are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our mobile application. The information they collect may be associated with your personal information or they may collect information, including personal information, about your online activities over time and across different mobile applications and other online services. They may use this information to provide you with interest-based (behavioral) advertising or other targeted content.

Pioneer Advisory does not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly. For information about how you can opt out of receiving targeted advertising from many providers, see "How Pioneer Advisory Uses Your Information".

How Pioneer Advisory Uses Your Information

Pioneer Advisory uses information that Pioneer Advisory collects about you or that you provide to us, including any personal information:

  • To present our mobile application and its contents to you.
  • To provide you with information, products, or services that you request from us.
  • To fulfill any other purpose for which you provide it.
  • To provide you with notices about your account or subscription, including expiration and renewal notices.
  • To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
  • To notify you about changes to our mobile application or any products or services Pioneer Advisory offers or provides through it.
  • To allow you to participate in interactive features on our mobile application.
  • In any other way Pioneer Advisory may describe when you provide the information.
  • For any other purpose with your consent.

Pioneer Advisory may use the information Pioneer Advisory has collected from you to enable us to display advertisements to our advertisers' target audiences. Even though Pioneer Advisory does not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria.

Disclosure of Your Information

Pioneer Advisory may disclose aggregated information about its Users, and information that does not identify any individual, without restriction.

Pioneer Advisory may disclose personal information that Pioneer Advisory collects or you provide as described in herein:

  • To our subsidiaries and affiliates.
  • To contractors, service providers, partners, and other third parties Pioneer Advisory uses to support our business.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Pioneer Advisory's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Pioneer Advisory about our mobile application users is among the assets transferred.
  • To third parties to market their products or services to you if you have not opted out of these disclosures.
  • To fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.
  • With your consent.

Pioneer Advisory may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply this Agreement and other agreements, including for billing and collection purposes.
  • If Pioneer Advisory believes disclosure is necessary or appropriate to protect the rights, property, or safety of Pioneer Advisory, our customers, or others. This includes exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.

Choices About How Pioneer Advisory Use and Disclose Your Information

Pioneer Advisory strives to provide you with choices regarding the personal information you provide to us. Pioneer Advisory have created mechanisms to provide you with the following control over your information:

  • Educational and informational mailings from the Company. If you do not wish to have your email address used by the Company to deliver you educational and informational mailings, you can opt-out by sending us an email stating your request to support@pitrade.com. If Pioneer Advisory has sent you an educational or informational email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a subscription, registration, product service experience or other transactions.
  • Promotional Offers from the Company. If you do not wish to have your email address used by the Company to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to support@pitrade.com. If Pioneer Advisory has sent you a promotional email, you may send us a return email asking to be omitted from future email distributions. This opt out does not apply to information provided to the Company as a result of a subscription, registration, product service experience or other transactions.
  • Targeted Advertising. If you do not want us to use information that Pioneer Advisory collects or that you provide to us to deliver advertisements according to our advertisers' target-audience preferences, you can opt-out by sending us an email stating your request to support@pitrade.com.

Pioneer Advisory does not control third parties' collection or use of your information to serve interest-based advertising. However these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative ("NAI") on the NAI's website.

Accessing and Correcting Your Information

You can review and change your personal information by logging into PiTrade and visiting your account profile page.

You may also send us an email at support@pitrade.com to request access to, correct, or delete any personal information that you have provided to us. Pioneer Advisory cannot delete your personal information except by also deleting your user account. Pioneer Advisory may not accommodate a request to change information if Pioneer Advisory believes the change would violate any law or legal requirement or cause the information to be incorrect.

If you delete your User Contributions from PiTrade, copies of your User Contributions may remain viewable in cached and archived pages, or might have been copied or stored by other mobile application users.

Residents of certain states may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

Your State Privacy Rights

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

  • California, Colorado, Connecticut, Delaware, Florida, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia provide (now or in the future) their state residents with rights to:
  • Confirm whether Pioneer Advisory processes their personal information.
  • Access and delete certain personal information.
  • Correct inaccuracies in their personal information, taking into account the information's nature processing purpose (excluding Iowa and Utah).
  • Data portability.
  • Opt-out of personal data processing for:
    • targeted advertising (excluding Iowa);
    • sales; or
    • profiling in furtherance of decisions that produce legal or similarly significant effects (excluding Iowa and Utah).
  • Either limit (opt-out of) or require consent to process sensitive personal data.

The exact scope of these rights may vary by state. To exercise any of these rights please send us an email at support@pitrade.com.

Data Retention Periods

Pioneer retains personal data only for as long as necessary to fulfill the purposes outlined in this Privacy Policy or to comply with applicable legal, regulatory, or contractual obligations. The retention periods for key data categories are as follows:

Financial and Transaction Data:

  • Retention Period: Retained for six (6) years after the end of the financial year in which the transaction occurred, in accordance with tax and accounting regulations.
  • Purpose: To meet regulatory requirements for financial reporting and audits.

Marketing Data:

  • Retention Period: Retained until you withdraw your consent or opt out of marketing communications.
  • Purpose: To provide updates, offers, and other relevant communications as per user preferences.

Support and Inquiry Data:

  • Retention Period: Retained for two (2) years following the resolution of the inquiry or support ticket.
  • Purpose: To ensure quality assurance and track repeated issues for service improvement.

Cookie and Analytics Data:

  • Retention Period: Retained for a maximum of thirteen (13) months, unless otherwise specified by applicable laws or regulations.
  • Purpose: To analyze user behavior and optimize PiTrade experience.

Legal and Compliance Data:

  • Retention Period: Retained for seven (7) years from the date of collection or as required by applicable legal and regulatory obligations.
  • Purpose: To respond to legal claims, prevent fraud, and ensure compliance with applicable laws.

Deletion and Anonymization

When the retention period for specific data expires, we will securely delete, anonymize, or aggregate the data, ensuring it is no longer identifiable or linked to any individual.

You are free to remove privately supplied personal information such as your email or password from our records at any time, but IP addresses will remain in logs until purged.

Data Security

Pioneer Advisory has implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our secure servers behind firewalls.

The safety and security of your information also depends on you. Where Pioneer Advisory has given you (or where you have chosen) a password for access to certain parts of our mobile application, you are responsible for keeping this password confidential. Pioneer Advisory asks you not to share your password with anyone. Pioneer Advisory urges you to be careful about giving out information in public areas of PiTrade. The information you share in public areas may be viewed by any user of PiTrade.

Unfortunately, the transmission of information via the internet is not completely secure. Although Pioneer Advisory does its best to protect your personal information, Pioneer Advisory cannot guarantee the security of your personal information transmitted to our mobile application. Any transmission of personal information is at your own risk. Pioneer Advisory is not responsible for circumvention of any privacy settings or security measures contained on PiTrade.

Changes to Our Privacy Policy

It is our Policy to post any changes Pioneer Advisory makes to our Privacy Policy on this page with a notice that the Privacy Policy has been updated on PiTrade home page. If Pioneer Advisory makes material changes to how Pioneer Advisory treats its users' personal information, Pioneer Advisory will notify you through a notice on PiTrade home page. The date the Privacy Policy was last revised is identified at the top of the page. You are responsible for ensuring Pioneer Advisory has an up-to-date active and deliverable email address for you, and for periodically visiting our mobile application and this Privacy Policy to check for any changes.

Contact Information

To ask questions or comment about this Privacy Policy and our privacy practices, or to register a complaint or concern, please contact us at: support@pitrade.com

Copyright © Pioneer Investing Inc. All rights reserved. PiTrade is the property of Pioneer Investing Inc., and is protected by United States and international copyright, trademark, and other applicable laws. This includes the content, appearance, and design of PiTrade, as well as the trademarks, product names, graphics, logos, service names, slogans, colors, and designs.

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