Your Data, Your Rights: Nurp’s Privacy Commitment

We value your trust. This Privacy Policy explains how Nurp collects, uses, and protects your personal information—ensuring transparency and compliance with global data privacy standards.

SECTION 1

Overview

‍‍At NURP LLC (“Nurp,” “we” or the “us”), we take privacy issues seriously. By ensuring that you are aware of and understand the Privacy Policy (“Policy”), we can provide you with better service. Please take a moment to read the following Policy to learn how we handle your Personal Information (defined in Section 2).

SECTION 2

What is Personal Information?

“Personal Information” means any data or information that is:

  • related to or is identifiable to you
  • describes, is or could be reasonably associated or linked to you, either directly or indirectly. 

Personal Information includes some of the categories of information listed in section 5 below, including, but not limited to, name, address, date of birth, credit card numbers, or any other identifying information, such as an IP address, cookie ID or other online or physical identifiers. “Personal Information” is only information relating to humans, not entities. Not all of the data we collect on you is classified as “Personal Information.”

SECTION 3

Why do we collect Personal Information? 

Nurp collects Personal Information for the following reasons: 

  • to improve the manner by which we operate
  • to improve our products and services
  • to adhere to any legal or regulatory obligations we or our principals or affiliates may have
  • to promote our products and services through marketing and ad campaigns
  • to market, offer, and license our products and services
  • to communicate with you about our products and services
  • to fulfill any contractual obligations
  • to process any payments under any agreements with you (if applicable)
  • to provide effective, timely customer support when needed

We will never rent or sell any of the Personal Information we collect from you to third parties, and we do not share your Personal Information except as set forth in this Policy or as otherwise agreed with you.

You will be prompted to accept this Privacy Policy in various agreements with us and you must accept the Privacy Policy in order to license any of our products and/or receive any of our services. By agreeing to our Terms & Conditions, you hereby agree to this Privacy Policy. 

SECTION 4

When and how do we collect personal information? 

Nurp collects Personal Information in a variety of ways when you interact with Nurp, its affiliates, and its vendors, including:

  • when you fill out an inquiry form on Nurp’s website (the “Site”) 
  • when you register or create an account on the Site
  • when you subscribe to Nurp’s software or when you participate in one of Nurp’s programs
  • when you enter into any agreements with Nurp
  • when you use Nurp products or services
  • when you use Nurp’s platform on the Site
  • when you pay for any of Nurp’s products or services 
  • when you visit the Site or webpages of certain Nurp’s partners or vendors
  • when you enter into contests, promotions, or sweepstakes; 
  • when you subscribe to a newsletter or desire to be added to our mailing lists for other products or services
  • when you attend or register to attend any of our webinars 
  • when you correspond, contact, or otherwise interact with us or the Site 
  • when you provide feedback in any of Nurp’s online surveys

Targeted marketing

When you interact with the Site, log in, register, or open our emails, we (or our service providers) may also collect information about your device and browser. This includes attributes like device type, browser type, IP address, and the pages you visit on the Site. We use this data to deliver more relevant ads and communications through various channels like online display media, email, phone calls, or direct mail. You have the right to opt-out of this targeted marketing. Please visit here to exercise this option.

SECTION 5

What kind of Personal Information do we collect?

Personal Information we collect may include your:

  • name
  • e-mail address
  • phone number
  • address and/or country of residence
  • Hubspot ID
  • brokerage ID
  • nationality
  • country and/or place of birth 
  • date of birth 
  • product preference information
  • billing information (address, credit card information, ACH information)
  • demographic information provided by you (such as language, gender and age, and, if applicable, content preferences and personalization information) 
  • personal interest information. 

On occasion, we may ask for additional information to enable us to provide you with  access to, and use of certain information, materials and services and for the purposes listed in this Policy. Nurp may combine information about you that we have with the information we obtain from business partners, third party vendors, or other companies.

SECTION 6

What are cookies and how do we use them?

‍Cookies are small data files that write to your hard drive for record keeping purposes when you visit a website. Cookies allow Nurp to measure traffic activity as well as to improve your user experience, for example by remembering your passwords and viewing preferences. Like other major websites, Nurp uses cookies to provide you with a tailored experience when visiting Nurp and using our products and services.

We treat any Personal Information that may be contained in cookies with the same level of confidentiality as other information you provide to us. If you wish to disable cookie functionality, you may do so by changing the security settings on your browser. However, portions of the Site may not function or function as efficiently, without them.

SECTION 7

What information is collected from other sources?

‍Social Media Widgets: The Site includes social media features, such as the Facebook Like button, and widgets, such as the Share This button or interactive mini-programs that run on the Site. These features may collect your Internet protocol address, which page you are visiting on the Site, and may set a cookie to enable the feature to function properly. Social media features and widgets are either hosted by a third party or hosted directly on the Site. Your interactions with these features are governed by the privacy statement of the companies that provide them.

Information from Third Parties: We may also obtain other data, including Personal Information, from third parties (e.g., vendors), and combine that with Personal Information we collect on you. For example, we may collect Personal Information through vendors that are used in the offering or licensing of Nurp’s products and services, such as third-party payment processors. 

SECTION 8

How do we protect your Personal Information?

‍Information From Third-Parties/Vendors: ‍ Any access that we may have to such information from a third-party services, including social media or authentication service is done in accordance with the authorization, privacy, and security procedures determined by that third-party/vendor.

If you authorize us to connect with a third-party service, we will access and store your name, email address(es), current city, profile picture URL, and other Personal Information that the third-party service providers/vendors makes available to us, and use, process, and disclose it in accordance with this Policy. You should check your privacy settings on these third-party service providers to understand and change the information sent to us through these services. 

Payments: Nurp uses third party vendors to process the payments of its customers of its products and services. ‍Nurp safeguards the security of the data you send us with physical, electronic, and managerial procedures. We urge you to take every precaution to protect your Personal Information when you are on the internet. To make purchases from the Site, you must use an SSL-enabled browser. We use industry-standard Secure Sockets Layer (SSL) encryption through third-party vendors on web pages in order for its customers to complete a purchase. This is designed to protect the confidentiality of your Personal Information and credit card information while it is transmitted over the internet.

While Nurp takes precautions to ensure the security of your data, no one can completely guarantee the safety of data transmitted over the internet. It is important that you take steps to ensure the safety and security of your Personal Information, for example by not sharing passwords, login details, or other Personal Information, and other data relevant to your Nurp account.

SECTION 9

‍What are the legal reasons we collect and disclose certain information?

‍‍Nurp collects and discloses your Personal Information for the following reasons:

  • To comply with laws applicable to you, Nurp, its principal(s), and partners
  • To perform its obligations under any agreement 
  • Delivery and billing for our products and services, and to communicate with you concerning your account and customer service issues. This may include verifying authorization of credit card usage before any purchase of content or services 
  • Improving our products and services by providing personalized content recommendations, language and location customization, and/or personalized help and instructions 
  • Requesting you to participate in surveys about products, services, news and events
  • Offering and licensing to you any of Nurp’s products or services
  • Marketing strategy and planning, and ad campaigns 
  • Offering you product upgrades, content, services and other training courses for you to purchase
  • Promoting any contests, sweepstakes, and giveaways
  • Providing you with a more personalized experience based on your Personal Information, such as your language preferences, zip/postal code, country locations, and any content or other preferences you provide
  • Providing you with news, free newsletters, updates, targeted advertising, promotions, and special offers
  • To better understand the performance of our products and how our products and services are used, including internet traffic patterns and what types of products are most popular with users of our products and services
  • Providing anonymous reporting for internal and external partners 
  • Facilitating your participation in our online forums and helping to manage improper behavior by individuals using the forums.

SECTION 10

To whom and when will we share your information?

Vendors: Nurp may share your personal information with trusted third-party vendors and partners who work with Nurp. These vendors and partners are provided with your Personal Information to help Nurp for the various reasons explained in Sections 3, 4 and 9 of this Policy.  They are contractually required to keep this Personal Information secure and will use and store the Personal Information in accordance with the agreement between Nurp and the third-party vendor. 

Products and Services: Nurp may send personal information about you to other vendors, companies or people when we need to share your information in order to provide the product or service you have requested or to perform our duties under an agreement with you. However, these companies are only permitted to use the personal information pursuant to the terms of such an agreement.

Order of a Competent Authority: Nurp may also disclose your Personal Information if required to do so by law or in the good faith belief that such action is necessary to: 

  • comply with law or legal process or if requested by duly authorized public authorities
  • comply with the order of a government authority, competent judicial authority or arbitrator in any jurisdiction or arbitration center
  • comply with legal process served on Nurp
  • protect and defend the rights or property of Nurp, its principals, employees, agents, or officers, or our affiliated companies, their principals, employees, officers,  and agents
  • enforce our terms of use or any other agreement entered into by Nurp or its principals or affiliates
  • protect against fraud or other illegal activity or for risk management purposes
  • permit us to pursue available remedies or limit the damages that we may sustain
  • act in urgent circumstances to protect the personal safety of users of NURP products or the public at large. 

Insolvency, Mergers & Acquisitions: If Nurp should ever file for bankruptcy, or become insolvent, or be acquired by a third party, or merge with a third party, or sell all or part of its assets, or transfer substantially all or part of its relevant assets to a third party, then Nurp is entitled to share the Personal Information and all other information you have provided through the products and service to potential and subsequent business and merger partners.

Cookies: Nurp may share “cookie” and other anonymous data about traffic patterns or usage collected on Nurp with affiliated companies, its business partners or with third-party advertisers, vendors, or ad networks. Any data shared is anonymous and does not identify any user.

Third-Party Advertising: Nurp may also include third party advertising. These third parties’ websites and advertisers, or the internet advertising companies that work on their behalf, may use technology such as web beacons and cookies to send (or “serve”) the advertisements that appear on the Site directly to your browser. They automatically receive your IP address when this happens. They may also use cookies, JavaScript, electronic images and other technologies to deliver advertisements, collect information about the effectiveness of their advertisements, and to collect anonymous information about your visits to the Site, such as the number of times you have viewed an ad (but not your name, address, or other Personal Information). If you would like more information about this practice, as well as your choices about not having this information used for online behavioral advertising by these ad networks, click here: OPT_OUT

Third-party websites: The Site may also contain links to other websites and products. Nurp is not responsible for the privacy practices or the content of such third-party websites or products. Please visit the privacy policies of these third party websites in order to understand their privacy policies and data collection practices. 

SECTION 11

What rights do you have regarding your Personal Information?

 You always have the right to request information about your stored Personal Information, its origin, its recipients, and the purpose of its collection at no charge. You also have the right to request that the Personal Information (defined in Section 1) that we store be corrected, blocked, or deleted. However, we reserve the right to not honor your request to delete or erase the Personal Information for different reasons, including those provided under applicable law. 

You can contact us at any time to request that your information is corrected, blocked or deleted by writing to us on: support@nurp.com. You can also reach out to us at support@nurp.com if you have further questions about the issue of privacy and data protection. Between the time that your email is sent to the address listed above and the time we receive and process your request, the Personal Information processed may still be legally processed. 

Many Personal Information processing operations are only possible with your express consent. You may request to revoke your consent at any time with future effect.

Opt-out: If you no longer wish to receive communications from Nurp, specifically communications relating to Nurp’s marketing, you can opt-out from receiving such messages in the future by following the instructions in the message or contacting us at support@nurp.com. With respect to the Site’s use of cookies and other similar technologies, by adjusting settings on your browser, you may elect not to allow cookies to be places, and thus opt-out of certain features of the Site and the Site’s automatic collection of certain data and Personal Information about you.

You may also adjust your advertising preferences on various social media websites by adjusting your settings on the Nurp platform. 

European Union and EEA: References to “Personal Information” under this Section shall mean “Personal Data” with respect to all EU “Data Subjects” (as defined under the EU General Data Protection Regulation (“GDPR”)). 

If you are accessing the Site from the European Economic Area (“EEA”), which includes the European Union, Iceland, Liechtenstein, and Norway, or you are a citizen of a member state of the European Economic Area, you have the following rights under GDPR and you can exercise the rights according to the terms under the GDPR:

Right to be informed about the collection and use of your Personal Information

Right to access your Personal Information (Article 15 of the GDPR)

Right to have any inaccurate Personal Information corrected (Article 16 of the GDPR)

Right to have your Personal Information erased (Article 17 of the GDPR) 

Right to restrict use of your Personal Information (Article 18 of the GDPR) 

Right to Personal Information portability (Article 20 of the GDPR)

Right to object to the processing of your Personal Information (Article 21 of the GDPR)

SECTION 12

How long does Nurp store your Personal Information? 

Subject to Section 11, Nurp will store your Personal Information for the minimum time permissible under applicable law and as is necessary in order to achieve our regulatory and legal obligations. Third-parties processors to whom your Personal Information is disclosed (e.g., third-party vendors such as payment processors) shall store your Personal Information in accordance with their own privacy policies. 

SECTION 13

Community Forums:

Legal basis for processing (EEA visitors only): References to “Personal Information” under this Section shall mean “Personal Data” with respect to all EU “Data Subjects” GDPR. If you are a visitor from the European Economic Area, our legal basis for collecting and using the Personal Information described above will depend on the Personal Information concerned and the specific context in which we collect it. However, we will normally collect Personal Information from you only where we need the Personal Information for one of the following reasons:

  •  to perform a contract with you (e.g. to provide you with services or license our products)
  • where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms 
  • where we have your consent. 

In some cases, we may also have a legal obligation to collect Personal Information from you. If we ask you to provide Personal Information to comply with a legal requirement or to perform a contract with you, we will make this clear at the relevant time and advise you whether the provision of your Personal Information is mandatory or not (as well as of the possible consequences if you do not provide your Personal Information).

Similarly, if we collect and use your Personal Information in reliance on our legitimate interests (or those of any third party), we will make clear to you at the relevant time why we need to use your Personal Information. If we process Personal Information in reliance on your consent, you may withdraw your consent at any time. If you have questions about or need further information concerning the legal basis upon which we collect and use your Personal Information, please contact us at support@nurp.com. 

Compliance with Laws and Law Enforcement Requests, Protection of Our Rights

In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We may disclose Personal Information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. We may also share such Personal Information if we believe it is necessary in order to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of any of our agreements, or as otherwise required by law. 

Testimonials

From time to time, we may post testimonials on the Site that may contain Personal Information. We obtain your consent to post your name along with your testimonial. If you wish to update or delete your testimonial, you can contact us at support@nurp.com.

Interactive Areas 

The Site may offer publicly accessible blogs, community forums, comments sections, discussion forums, or other interactive features (“Interactive Areas“). You should be aware that any information that you post in an Interactive Area might be read, collected, and used by others who access it. To request removal of your Personal Information from an Interactive Area, contact us at support@nurp.com. In some cases, we may not be able to remove your Personal Information, in which case we will let you know if we are unable to do so and why. Notice concerning the party responsible for this website. The party responsible for processing data on this website is: NURP LLC, 1000 Brickell Avenue, Suite 750, Miami, FL 33131. Phone Number: (786) 977-2443. Email: support@nurp.com.

Direct Marketing: California Residents only

If you are a resident of California, California law permits you to request certain information regarding the disclosure of your Personal Data by Nurp, or its affiliates and subsidiaries, to a third-party for direct marketing purposes. To make such a request, please email us at support@nurp.com.

Child privacy

We respect children’s privacy in particular. We do not knowingly target or intentionally collect personally identifiable information from children under the age of 13. By using the Site, you have represented and warranted that you are either 18 years of age or using the Site with the supervision of a parent or guardian. If you are under 13, you may not use the Site. If you become aware that your child has provided us with Personal Information without your consent, please email us at support@nurp.com. If you would like to contact us for any reason regarding our privacy practices, please e-mail us at the following address: support@nurp.com. 

SECTION 14

Where does Nurp process your Personal Information? 

Nurp’s servers are hosted in the US and your Personal Information is processed in the US. We may process your Personal Information in other jurisdictions where our vendors and service providers operate.

SECTION 15

Updates

We may change this Policy at any time. If we make material changes to this Policy, we will prominently post that the Policy has changed.

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AI Quantitative
Researcher

Bingham Zhou

Bingham Zhou, CFA, has over 15 years of experience as a quantitative researcher. His expertise spans systematic equity strategies, CTA trend-following, and interest rate proprietary trading in both U.S. and Asian markets. He holds advanced degrees from MIT, Carnegie Mellon, and Yale.

Portrait of a man with shoulder-length light brown hair and stubble, wearing a white shirt and black blazer against a gray background.
Quant–Investment Strategist
Greg doscher

Greg Doscher was a CFO for many years who built out many quantitative strategies and investment tools to manage and enhance risk adjusted returns in the company’s pension plan. Prior to joining Nurp, he consolidated his skills in coding and discretionary trading to develop a comprehensive and fully automated algorithmic trading system deployed across 200+ futures markets and cryptocurrencies that encompassed all of the trading strategies he had honed over the last 22 years in finance

Quant–Investment Strategist
Marcin Borratynski

Marcin was Head of Quant IT at the USD 4bn+ CERN Pension Fund, where he spent nearly a decade building quantitative asset allocation systems and implementing algorithmic investment strategies for a multi-asset institutional portfolio.Before joining Nurp Marcin was also Senior Quant Strategist at Evooq, a Swiss-based fund managing four strategies across equities, gold, and equity derivatives.Marcin holds a degree in Computer Science an MBA from the University of Geneva and the Certificate in Quantitative Finance (CQF).

Product Manager

Abhayjit Anand

Abhay has worked with Nurp since 2022. As a Product Strategist, he focuses on building, refining, and commercializing algorithmic trading strategies. He brings seven years of experience in financial trading – combining macro research, technical analysis, quantitative strategy development, and market psychology. Alongside his work at Nurp, Abhay also serves as an Investment Analyst at Orca Capital. Before entering financial markets professionally, he spent eight years at IBM, including three years in the AI & data division as a Delivery Lead managing complex implementation projects.