Privacy Policy

Your confidentiality is important to us, and Commence Consulting, LLC (“Commence” or “we” or “us”) is firmly committed to protecting the privacy of the users of (the “Site”).

Please read this Privacy Policy before using the Site or its services. By using the services provided both online and offline, you are bound by this policy, which may be modified from time to time. If you do not agree to abide by this policy, you may not use the Site or the services provided by Commence.


“Personal Information” is information that you provide to us which personally identifies you, such as your name, email address or billing information, or other data, which can be reasonably linked to such information by Commence. Personal Information is different than Aggregate Non-Personal Information. “Aggregate Non-Personal Information” is information that is recorded about users and collected into groups so that it no longer reflects or references an individually identifiable user. Aggregate Non-Personal Information includes all investment-related information that you provide us and all reports we provide you so long as that information is not associated with you or your User account.

We do not collect any Personal Information from a visitor to the Site unless that visitor expressly and intentionally provides it. Commence does not collect any Personal Information revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, health, or sex life, unless such information is required to comply with applicable laws or regulations, such as those relating to affirmative action. If you are simply browsing the Site, we do not gather any Personal Information about you. Commence may collect Aggregate Non-Personal Information to assist Commence in improving the services offered through the Site.


Commence may automatically collect your browser type and browser software version to tailor the presentation of the Site to your platform and to maintain a record of your activity on the site. Commence may also use cookies to enable Users to specify unique preferences and to track User trends and patterns. Users always have the option of disabling cookies via their browser preferences. If you disable cookies on your browser, please note that some parts of our site may not function or may be considerably slower. As an automatic process, our web server software may record a log file of IP addresses that access the Site. We may also collect IP address information but do not ordinarily link IP addresses to Users’ Personal Information, other than for statistical analysis as needed. However, we can and will use IP addresses to identify a User when we, in our sole discretion, determine that it is necessary to enforce compliance with our Terms and Conditions or to protect our service, site, customers or others.


We use Personal Information for our own internal purposes including contacting you via email to inform you about updates to the Site. We do not rent or sell our Users’ Personal Information to third parties. We may, however, provide you with the opportunity to receive communications via email. To opt-out from any non-critical email messages, simply click on the “unsubscribe” link contained within the email.


The primary purpose of collecting Personal Information is to provide you with a safe and seamless experience and to allow you to keep track of your own user related information on the Site.


We use links throughout the Site to provide you with the opportunity to contact us via e-mail or through other means to ask questions, request information, and register or provide comments and suggestions. You may also be offered the opportunity to have one of our representatives contact you personally to provide additional information about our services. To do so, we may request additional Personal Information from you, such as your name and telephone number, to help us satisfy your request.


Commence sends all newly registered members a welcome email to verify their email addresses and other registration information. We also communicate with registered members via personal emails.   Registered members cannot unsubscribe from service announcements that discuss upcoming changes that affect their accounts.


Commence is not responsible for the privacy practices or the content of any other web sites to which the site links or which link to the site. By clicking on a link, logo, advertisement or other item, please note that you may no longer be on the Site. To check what Internet location you are on, note the URL at the top and/or bottom of your browser. We encourage you to read the posted privacy statement of that web site when browsing to another website, as this Privacy Policy does not apply to websites other than the Site.


Commence may engage third-party intermediaries to provide our members with additional offerings and services. Commence makes no representations regarding these third parties and their use of Personal Information. Please refer to the third-party’s web site and terms of service for their specific privacy policies.


Your password is the key to your account. Use unique numbers, letters and special characters, and do not disclose your password to anyone. Commence will not contact you via email to ask for your username or password. If you do share your username and password or your Personal Information with others, remember that you are responsible for all actions taken in the name of your account. If your password has been compromised for any reason, you should immediately notify Commence and change your password.


Most User Information is User updatable in the Membership section of the Site. If you cannot update the information yourself, please notify us of any changes or errors related to any of your information that we have on file.


Your information is stored on our servers located in the United States. We treat data as an asset that must be protected and use tools (encryption, passwords, physical security, etc.) to protect your Personal Information against unauthorized access and disclosure. However, as you probably know, third parties may unlawfully intercept or access transmissions or private communications, and other users may abuse or misuse your Personal Information that they collect from the Site. We will use commercially reasonable methods to keep Personal Information securely in our files and systems. Please note that with current technology, we cannot guarantee the security of your data as it travels over the Internet.


As part of registration, you will provide specific information about yourself. Some of the information requested in the registration is mandatory. We strongly encourage you to complete your entire profile as this may directly affect your ability to use the Site.


The Site is controlled, operated and administered by Commence from its offices within the United States of America and this Policy is provided in accordance with and subject to applicable U.S. law. If you are based outside the United States and decide to access the Site from your location outside of the United States, you hereby agree to be subject to this Notice and waive all other privacy-related rights you may have.


We save your Personal Information until your account with us is terminated. To terminate membership, you may submit a request in writing to If you terminate your membership, your Personal Information will be deleted from our records and, after deletion, cannot be recovered. You may also continue to receive email communications for a short period of time until we have updated all of our databases. Notwithstanding the above, we will maintain information on users who have been removed for violating any of our agreements.


Though we make every effort to preserve user privacy, we may need to disclose your Personal Information when required by law when we have a good-faith belief that such action is necessary to comply with a current judicial proceeding, a court order or legal process. If Commence is served with legal documents that it believes will require it to disclose your Personal Information, we will either seek legal protection to avoid disclosure or notify you of the request to give you an opportunity to object to the disclosure of your Personal Information.


If you have any questions about this Privacy Agreement or the practices of the Site, you may email us at with any questions you have.

Please note that this policy may be amended from time to time. You should check back for the most current version before relying on any of the provisions in this privacy policy.

Last updated: February 15, 2013