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Privacy Policy

Updated January 06, 2023

This Privacy Policy describes how Nasdaq Private Market, LLC at 3 E 28th St, 7th Floor, New York, NY 10016, and its subsidiaries and affiliates (collectively, “NPM,” “we,” “our” or “us”), as data controller collects, uses, and discloses Personal Data about individuals (collectively, “users” or “you”) receiving our products and services, exploring or maintaining a business relationship with us (either directly or through an intermediary such as your financial services provider, your appointed legal or other representative, or your employer), and/or using our websites or online features (each a “Site” or collectively, our “Sites”). As used in this Privacy Policy, “Personal Data” means any information relating to an identified or identifiable natural person; Personal Data is intended to cover all information subject to personal data processing and privacy laws applicable to our business. To the extent required or permitted by applicable law, by visiting or using our Sites, you are consenting to us collecting and processing information about you in accordance with this Privacy Policy.

The Privacy Policy also describes your rights, where applicable, and how to exercise them. You may contact us at any time with questions related to our Personal Data processing and privacy via email at legal@npm.com.

INFORMATION WE COLLECT FROM YOU OR YOUR REPRESENTATIVE

We only collect information from you/your representative or about you that is reasonably necessary for us to provide the relevant product or service, business relationship, and/or communication consistent with the nature of such product, service, business relationship, and/or communication. Based on the specific products, services, business relationship, or Sites involved as well as requirements under applicable law, we may collect the following categories of Personal Data that you or your representative (such as your employer, financial services provider, legal representative, or company where you are an officer, director, or significant shareholder) provide to us:

  • Name;
  • Email address;
  • Telephone number;
  • Mailing address;
  • Company;
  • Title;
  • Business contact information;
  • Employment, company officer or director, or shareholder status;
  • Tax or National Identification Number;
  • Date of birth;
  • Trader identification, client identification, or trading “short code”;
  • Career or professional history and educational background;
  • Financial holdings information;
  • Your recorded voice (where you are advised in advance of the recording);
  • Photograph;
  • Payment information (e.g., bank account or credit card number);
  • Username and password;
  • Passport or government issued identification information (e.g., for identity verification purposes); and
  • Any other Personal Data you or your representative volunteers on or provides access to via any or our Sites and/or any NPM community forum, social media offering, or blog, including, but not limited to, information related to your use of the Sites and interests in certain products or services.

We may also automatically collect the following categories of information from devices (e.g., mobile, computer, laptop, tablet) used to visit or use our Sites (“Device Information”):

  • Internet Protocol (IP) address;
  • Device identifier;
  • Log files;
  • Cookies and similar technology;
  • Clear GIFs or pixel tags, or similar technologies as they may develop over time;
  • Flash LSOs; and
  • Other information as described in the Cookies section of this Privacy Policy.

Certain Device Information may be deemed Personal Data in accordance with applicable law. Personal Data and Device Information are collectively referred to as “information.”

INFORMATION THAT WE COLLECT ABOUT YOU

Based on the specific products, services, business relationship, or Sites involved (as well as requirements under applicable law), we may collect the following categories of Personal Data on our own or from third parties about you in accordance with applicable law:

  • Information about you available in news feeds, exchange data feeds, and other public data sources (including the public internet);
  • Information provided by relevant regulators, government agencies, and non-government credentialing or professional organizations;
  • Information related to your status under economic sanctions, anti-money laundering, and similar laws or other information that may impact our ability to engage in business with you or a company at which you are an employee, officer, director, or significant shareholder;
  • Information that you, your employer, or other representative makes publicly available via your personal or company website or in social media profiles;
  • Information related to your professional activities (such as consulting to public retirement funds) that is contained in documents released by a governmental body under Freedom of Information Act, Open Government License, or similar laws and regulations;
  • Information from event organizers for events that you have attended;
  • Information from companies providing professional contact information to their customers/subscribers; and
  • Other Personal Data to the extent permitted by applicable law and reasonably necessary for the performance of our business obligations, compliance with laws applicable to our business, or pursuit of our legitimate business interests.

HOW WE USE YOUR INFORMATION

The following is an overview of NPM’s purposes for processing Personal Data. Often due to the nature of the product or service involved or the context in which the Personal Data is used, it will be apparent how we intend to use the information. Additional information about processing related to a particular product or service may be separately posted on the relevant Site or contained in the applicable terms and conditions.

We may use the information we collect for the purposes identified below. To the extent required by applicable law, each purpose for the processing of Personal Data is substantiated by one or more lawful bases for processing. Unless otherwise identified with respect to a particular product or service, our processing is done based of one or more of the following:

Provide you (or your employer/represented company) with our services and products and communicate with you about your (or your employer/represented company) accounts or use of our products, services and/or Sites

  • Perform or enter into a contract
  • Legitimate business interests
  • Comply with a legal obligation
  • Consent

Process transactions through one of our services including, but not limited to, processing financial transactions initiated by your or your representative

  • Perform or enter into a contract
  • Comply with a legal obligation

Comply with our obligations as an exchange, clearinghouse, broker-dealer, and/or other regulated/licensed business.

  • Perform or enter into a contract
  • Comply with a legal obligation

Perform transaction and regulatory reporting requirements under applicable law

  • Perform or enter into a contract
  • Comply with a legal obligation

Perform our obligations as a trading venue and/or market operator including, but not limited to, conducting surveillance of issuers and trading activities, conducting disciplinary proceedings and reporting suspected to misconduct to regulators and other authorities

  • Perform or enter into a contract
  • Legitimate business interests
  • Comply with a legal obligation

Monitor for security threats and fraud involving the use of our products, services, Sites, or physical facilities

  • Legitimate business interests
  • Comply with a legal obligation

Maintain your status as a representative of an exchange or clearinghouse member or certified advisor to issuers

  • Perform or enter into a contract
  • Comply with a legal obligation

Register or establish an account for you (or the company for whom you are an employee, officer, or director) as a customer

  • Perform or enter into a contract
  • Legitimate business interests
  • Comply with a legal obligation

Register you (or your employer/represented company) to receive services or information through one or more of our Sites

  • Perform or enter into a contract
  • Consent

To the extent permitted by applicable law, identify you (or your employer/represented company) as a prospective customer for products or services and provide you with relevant information and/or invitations to events

  • Legitimate business interest
  • Consent

Manage our relationship with you (or your employer/represented company) as a customer, business prospect, and/or information recipient

  • Perform or enter into a contract
  • Legitimate business interest
  • Consent

To pursue or enforce our legal rights related to our business, products, services, or Sites and/or defend against claims made against us

  • Perform or enter into a contract
  • Legitimate business interest

Communicate with you (or your employer/represented company) about your account or use of our products, services, or Sites

  • Legitimate business interest
  • Consent

Create informational materials and statistical extracts for our products and services

  • Perform or enter into a contract
  • Legitimate business interest
  • Consent

Develop, provide content for, operate, deliver, and market our services and Sites

  • Perform or enter into a contract
  • Legitimate business interest
  • Consent

Develop and deliver marketing of our products and services and those of our advertisers, sponsors, and partners

  • Legitimate business interest
  • Consent

Improve the quality of our Sites and tailor them to your preferences

  • Legitimate business interest
  • Consent

Implement social networking features you have activated (e.g., Facebook “Like” button and LinkedIn integration) 

  • Consent


We also use your information for compliance with our company policies and procedures, for accounting and financial purposes, and otherwise as required or permitted by applicable law. If you do not provide us with information as described above, we may not be able to fulfill the applicable purpose of collection, such as completing a contemplated transaction, responding to your queries, or providing access to our Sites to you.

With respect to situations where we process Personal Data based on our legitimate business interest, to the extent required by applicable law, you have the right to object to the processing of your personal data based on a legitimate interest as legal basis. Please see the section below regarding your rights to find out more. Where processing is based on your consent, you have the right to withdraw that consent at any time.

AUTOMATED DECISION-MAKING

NPM does not engage decision-making based solely on automated processing, including profiling, which produces legal effects concerning an individual or similarly significantly affects an individual.

As part of NPM’s surveillance programs for its exchanges, we utilize certain software that uses machine intelligence and learning to identify situations that potentially constitute market abuse, insider trading, fraud, or violations of our published rules. Such software relies on identifying patterns indicating misconduct based on past activity. The conduct involved may include conduct by a corporate member, trading algorithm, or individual action. Alerts are referred for investigation by our surveillance team which determines which actions to take based on our published rules and applicable law.

HOW WE SHARE YOUR INFORMATION

From time to time, to the extent permitted by applicable law and subject to any contractual limitations on sharing Personal Data set forth in a relevant contract for products and services, we may share your information with our affiliates, subsidiaries, business partners, customers/members (such as where we process your Personal Data in connection with your role with your employer or financial services provider), third-party service providers, and authorities in the following circumstances:

  • Affiliates, Subsidiaries, Business Partners, and Customers. We may share your information with our business units, affiliates, subsidiaries, business partners, and customers in the US and worldwide for purposes identified above, including Nasdaq, Inc. To the extent required or permitted by applicable law, by visiting or using our Sites or otherwise providing us with your information, you consent to this sharing of your information. Where such consent exists, to opt-out of such sharing, please contact us via email at legal@npm.com or at the location in the Contact Us section below.
  • Service Providers. We may share your information with third parties who perform functions on our behalf (e.g., hosting or operating our services or Sites, processing credit card payments, sending email marketing communications, data analysis, or any financial institutions or business partners with whom we jointly offer products or services). We do not authorize these third parties to use your information for purposes other than for which it has been provided, and do not authorize these third parties to disclose that information to unauthorized parties. We require these third parties to maintain appropriate security to protect your information from unauthorized access or processing.
  • As Required or Appropriate by Law. We may disclose your information to regulatory authorities (including other self-regulatory organizations), courts, and government agencies where we believe that doing so would be in accordance with, or permitted or required by, any applicable law, regulation, or legal process, to defend the interests, rights, and/or property of NPM or others, or to respond to emergencies. We may also disclose your information as part of an information-sharing arrangement established under applicable law such as one developed by a government authority to combat financial crime.
  • Business Transfers. We may transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, brands, affiliates, subsidiaries, or other assets. To the extent that such a transaction results in you being a current or prospective customer, vendor, or other third-party point-of-contact for both the portion of the business that is transferred and the portion that remains with NPM, your information may be both transferred to the transferee and retained by NPM. To the extent permitted by applicable law, we may share information with a prospective buyer or transferee of the business as part of the diligence process provided that we require any such third party to maintain the confidentiality of your information and protect it with appropriate technical and organizational security measures. 

We may share your information with other parties as directed by you or subject to your consent. We may also share and otherwise process aggregated information or de-identified information that does not identify you individually with other parties. For example, from time to time, we may utilize survey information collected from you on an aggregated or otherwise not individually-identifiable basis. We also use this aggregated or de-identified information for our various business purposes, including the creation and sale of other products and services to our clients and potential clients. This aggregated or de-identified information is not traceable to any particular client or user and will not be used by a third party to contact you.

Except as described herein, we do not share, sell, rent, or trade your information to our service providers or business partners for their own direct marketing purposes, unless we have explicitly given you the option to opt-in or opt-out of such disclosures. 

MARKETING COMMUNICATIONS

We process Personal Data within the scope of our marketing and market segmentation. With market segmentation, we mean that we categorize our customer base based on professional affiliations and functions, alignment with our services and products and information gathered from public sources of information. For customers or users of our Sites, we may also use information gathered from your use of our products, services, and/or Sites for marketing purposes to market our products and services to you. You always have right to request that we stop using your personal data for direct marketing purposes.

If you no longer wish to receive marketing communications from us, you may opt-out of receiving marketing-related emails by: (1) using the unsubscribe method provided in our communications; (2) if you created an online account when you registered to receive our emails, you may log-in to your account on the applicable Site and make changes to your communication preferences; or (3) you can opt out by updating your preferences in the Email Alert section of our Sites. In particular, you have the right to object our use of your Personal Data for direct marketing and in certain other situations (in accordance with applicable law) by contacting us at legal@npm.com. If you are having difficulty unsubscribing from our email marketing communications using the above methods, please contact us as at legal@npm.com.

We will try to comply with your request as soon as reasonably practicable as required by applicable law. Please note that we may need to retain certain information for recordkeeping purposes, to complete any transactions that you began prior to your request, or for other purposes as required or permitted by applicable law. In addition, please note that even if you opt-out of receiving marketing communications from one or all of our Sites, we may need to send you service-related communications.

YOUR RIGHTS REGARDING YOUR PERSONAL DATA

To the extent required by applicable law, in our capacity as the controller of your Personal Data, we will also provide you with the opportunity to be informed of whether we are processing your Personal Data and at any time to access, correct, update, oppose, delete, block, limit, or object to our use of your Personal Data. The foregoing rights will be afforded to you free of charge (except to the extent that your requests are manifestly unfounded or excessive, in which case, we may charge an administrative fee or refuse to meet your request). Please note that legal obligations that apply to our business – for example, financial regulations that apply to us – may prevent us from immediately deleting parts of your information. To exercise your rights, please contact us as detailed under the Contact Us heading below.

To prevent fraudulent activity, we may require you to authenticate your identity when you contact us. We will try to comply with your request as soon as reasonably practicable and within timeframes required by applicable law. Please note that in some instances, due to the nature of the information that we receive, we may require you to provide additional information that will help us identify which information is yours. For requests subject to the European General Data Protection Regulation, we will respond to your request within one month of our receipt of it. We may extend this period by two further months taking into account the complexity of your request or the number of requests that we have received; we will inform you of any such extension within one month of receiving your request along with the reasons for the delay and information about your right to file a complaint with the supervisory authority.

The following sets out a summary of rights to the extent that your Personal Data is processed subject to applicable laws that provide such rights:

  1. Right to access, rectification, erasure, and restriction of processing. You have the right to request:
    • Access to your personal data. This means that you have the right to request information on our use of your Personal Data. You also have the right to request a copy of the Personal Data being processed at no cost. However, we may charge you a reasonable administrative fee to provide you with additional copies of the Personal Data. If you make your access request by electronic means such as email, we will provide you with the information in a commonly used electronic format.
    • Rectification of your personal data. We will at your request, or at our own initiative, rectify, anonymize, erase, or complement Personal Data that you or we discover is inaccurate, incomplete, or misleading. You also have the right to complete the Personal Data with additional data if relevant information is missing.
    • Erasure of your personal data. You have the right to request that we erase your Personal Data if we do no longer have an acceptable reason for processing the data. Given this, erasure shall be made by us if: (i) the Personal Data is no longer necessary for the purposes for which it was collected, (ii) we use your Personal Data with your consent and you withdraw your consent, (iii) you object to the processing of your Personal Data based on our legitimate interest and there is no overriding legitimate ground for the processing, (iv) the Personal Data has not been lawfully processed, (v) we are required to erase the Personal Data due to a legal obligation, or (vi) you are a child and we have collected the personal data in relation to the offer of information society services. 

However, there might be requirements under applicable law, or other compelling reasons, that prevent us from immediately erasing your Personal Data. In such cases, we will stop using your Personal Data for any other reasons than to comply with the applicable law or the relevant compelling reason.

  1. Right to restrict processing: This means that we temporarily restrict the processing of your Personal Data. You have the right to request restriction of the processing when:
    • you have requested rectification of your personal data in accordance with this Privacy Policy, during the period of time we are verifying the accuracy of the data,
    • the processing is unlawful and you do not want the Personal Data to be erased,
    • as data controller, we no longer need the Personal Data for the purposes for which it was collected, but you require us to retain the information for the establishment, exercise, or defense of legal claims, or
    • you have objected to our legitimate interest for the processing in accordance with this Privacy Policy, during the period of time we determine whether the legitimate interest overrides your privacy rights.

We will take all reasonable and possible actions to notify any recipients of your Personal Data regarding any rectification, erasure, or restrictions carried out by us. At your request, we will also inform you with which third parties we have shared your Personal Data.

  • Right to object to processing. You have the right to object to the processing of your Personal Data based on our legitimate interest. If you object to such processing, we will only continue with the processing if we have a compelling legitimate reason for the processing that outweighs your interest, rights, or freedoms, or if continued processing is necessary for the establishment, exercise, or defense of a legal claim.
  • Right to portability. You have the right to receive certain of your Personal Data in a structured, commonly-used, and machine-readable format and have the right to transmit those data to another controller. You only have this right when your personal data is processed by automated means and our legal basis for the processing is performance of a contract between you and us.
  • Right to lodge a complaint. You have the right to lodge any complaints regarding our processing of your personal data with the supervisory authority.

SECURITY OF YOUR INFORMATION

We take reasonable technical, administrative, and physical security measures to protect your information, including applying generally-accepted industry standards to protect the information submitted to us during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage is 100% secure, so we unfortunately cannot guarantee absolute security. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed under the “Contact Us” heading below.

INTERNATIONAL TRANSFERS

Some of the parties with which we may share your information, as detailed in “How We Share Your Information”, may be located in countries that do not provide an equivalent level of protection as your home country. Where required, NPM has implemented appropriate cross-border transfer solutions to provide adequate protection for transfers of certain personal information, including, but not limited to, the European Commission’s Standard Contractual Clauses (available at https://commission.europa.eu/publications/standard-contractual-clauses-international-transfers_en). To the extent permitted by applicable law, by using our Sites, and providing us information about you, you consent to the international transfer of information about you to the above parties.

RETENTION OF YOUR INFORMATION

We will retain your information for the period necessary to fulfill the purposes outlined in this Privacy Policy and as otherwise needed to comply with applicable law and recordkeeping requirements or to address any complaints, challenges, or legal or compliance matters related to the information.

COOKIES, WEB BEACONS, AND OTHER TECHNOLOGIES

When you use our Sites, we along with our affiliates, subsidiaries, and third-party service providers may use “cookies”, similar and other technologies as they may develop over time (e.g., log files, clear gifs, pixel tags, and Flash LSOs) (collectively, “technology”). This technology may involve placing small files/code on your device or browser that serve a number of purposes, such as remembering your preferences (e.g., language) and generally improving your experience on our Sites. Specifically, we may use such technology for purposes such as to:

  • Provide us with general analytics about our Sites, including demographic information in a non-identifiable form, in order to improve our Sites’ performance and customize users’ experience;
  • Enable us to help you make better use of our services or Sites such as by suggesting how you can improve your use of different features or functionality or help address technical issues that you encounter in using our services or Sites;
  • Support security measures, such as requiring re-login into your account or additional authentication when using a new device to access our Sites;
  • Measure the success of our marketing campaigns and compile statistics about the Site’s usage and email response rates;
  • Allow you to engage in our social media offerings on our Sites (e.g., Facebook “Like” button and LinkedIn integration); and
  • More effectively market our Sites and advertise other Sites that may be of interest to you. 

Cookies. A cookie is a small text file saved on your device or browser. Some of these cookies are necessary for the functioning of our Sites (known as “strictly necessary” cookies), while others are not (known as “non-essential” cookies). Some cookies (known as “persistent cookies”) will remain on your device until you delete them, while others (known as “session cookies”) are automatically erased when you exit your Internet browser. We do not link the information we store in cookies to your information.

You can set your device or browser to accept or reject most cookies, or to notify you in most situations that a cookie is offered so that you can decide whether to accept it. However, if you block cookies, certain features on our Sites may not function. Additionally, even if you block or delete Cookies, not all tracking will necessarily stop.

We may place or recognize technology on your browser or device when you visit our Sites for purposes of serving you targeted advertising (also referred to as “online behavioral advertising”). We also work with third-party advertising companies who place their own cookies or similar technology on your browser or device when you visit our Sites and other websites to serve customized advertisements to you as you browse the Internet. As noted above, you can set your device or browser to accept or reject most cookies, or at least notify you in most situations that the technology is offered. As an additional step, these advertising companies may participate in one of the following advertising industry self-regulatory programs for online behavioral advertising, with corresponding user opt-outs:

Please note that even if you reject such technology, you may continue to receive advertisements, but the advertisements will not be tailored to your browsing activities and interests.

Log Files. We automatically gather log files, such as your IP addresses, browser type, internet service provider, referring/exit pages, operating system, date/time stamp, and clickstream data when you use our Sites. We may combine information in log files with your information.

Clear GIFs (Web Beacons/Web Bugs/Embedded Pixels). Clear GIFs are embedded on our Sites and are about the size of the period at the end of this sentence. The information collected by these technologies is associated with other technology and information, but only for internal tracking purposes only. We do not disclose or divulge such linkages outside of NPM. 

Flash LSOs. Flash Local Storage Objects (“Flash LSOs” / “Flash Cookies”) display content based upon your preferences for how you like to view our Sites. Flash LSOs are different from browser cookies because of the amount of, type of, and how information is stored. Cookie management tools provided by your browser will not remove Flash LSOs. To learn how to manage privacy and storage settings for Flash LSOs, click here.

Third-party applications and APIs. We also offer and deliver services, content, or interactive features through and/or using third-party application programming interfaces, gadgets, and/or extensions that are hosted on our Sites or through other third-party websites or social networking platforms. When you use these services, products, applications, or otherwise connect with, or “accept” or “allow” third-party applications, networks, platforms, or services through our Sites, you are authorizing those third parties to receive your information and additionally to potentially share any or all of your information with us, based on your privacy or other settings on the particular third-party network or platform. Any information we receive by these means will be treated and/or processed according to this Cookie Statement.

REFERRALS

If you choose to use our referral service to tell someone about our products or services or Sites, we will ask you for your friend’s name and email address. We will send your referral a one-time email to invite him/her to access the Site or with information about the product or service, and store his/her email address for the sole purpose of sending this one-time email and tracking the success of our referral program. Your referral may contact us as detailed under the “Contact Us” heading below to request we remove this information from our database.

LINKS TO OTHER WEBSITES

Our Sites may contain links to other websites or services that are not owned or controlled by NPM, including links to websites of our advertisers, sponsors, and partners. This Privacy Policy only applies to information collected by our Sites. We have no control over these third-party websites, and your use of third-party websites and features are subject to privacy policies posted on those websites. We are not responsible or liable for the privacy or business practices of any third-party websites linked to our Sites. Your use of third parties’ websites linked to our Sites is at your own risk, so we encourage you to read the privacy policies of any linked third-party websites when you leave one of our Sites.

We may use third-party payment services to process purchases made through the Sites. If such service is made available and you wish to make a purchase through the Site, your Personal Data may be collected by the third party (and not by us). In that case, the information you provide to the third party will be subject to that third party’s privacy policy and not this Privacy Policy.

USE OF SITES BY CHILDREN

None of our Sites are targeted for use by children under the age of sixteen. We do not target any of our products or services or Site content/features for use by children of such age.

For California Consumers

If you reside in California, we are required to provide additional information to you about how we use and disclose your information, and you may have additional rights with regard to how we use your information. We have included this California-specific information below.

  1. CA Personal Information. Consistent with the “Information We Collect” section above, we collect certain categories and specific pieces of information about individuals that are considered “Personal Information” in California (“CA Personal Information“). Specifically, we may collect the following types of CA Personal Information:
    • Identifiers: name; email address; social media username; telephone number; mailing address; business contact information; tax or national identification number; date of birth; username and password; passport or government issued identification information (such as for identity verification purposes); identifiers assigned by NPM systems.
    • Commercial or trading-related information: products or services purchased, obtained, or considered; other purchasing or consuming histories or tendencies; financial holdings information; payment information (e.g., bank account or credit card number); transaction history; transactions, activities, or other behavior related to financial markets;
    • Internet or other electronic network activity information: computer and connection information; statistics on page views; traffic to and from the websites; device information; ad data; other standard weblog information.
    • Professional or employment-related information: company; title; employment, company officer or director, or shareholder status; trader identification, client identification, employer-assigned identification, or trading “short code”; identifiers issued by a licensing or regulatory organization; professional affiliations; career or professional history and educational background.
    • Legal and regulatory information: information related to your ability to participate in the US or other financial markets; information regarding your status under US or global economic sanctions, export control, or other trade control regimes; information related to law enforcement actions, fraud, cybersecurity, or other similar risks; where authorized related to certain NPM services, the results of background screening including anti-money laundering assessments.
    • Audio or visual information: your recorded voice (where you are advised in advance of the recording); photograph.
  2. Sources. We may collect certain categories of CA Personal Information from you and other third parties as described in the “Information We Collect” section above. The categories of third parties from whom we may collect CA Personal Information include the following:
    • Third-party partners;
    • Third-party applications (including, blogs, chat rooms, or social networks);
    • Advertising networks;
    • Government agencies and other self-regulatory organizations; and
    • Other companies or organizations, such as market research firms and data aggregators. 
  3. Purposes. We collect the CA Personal Information for the business and commercial purposes described in the “How We Use Your Information” section above. As described above in the “How We Share Your Information”, we also share and/or disclose your CA Personal Information as follows:
    • Sharing your CA Personal Information for business purposes: We may share the following categories of your CA Personal Information with service providers, third-party partners, customers, public or government authorities, and future business partners for our business purposes: Identifiers; Commercial or trading-related information; Internet or other electronic network activity information; Professional and other employment-related information; Legal and regulatory information; and, Audio or visual information. As described above, examples of business purposes include performing transactions and delivering our contracted services, providing you requested information or services, registering and maintaining accounts, managing our relationship with you or your employer, monitoring for security threats and fraud, and performing our legal and regulatory duties.
    • Sharing your CA Personal Information for other purposes: We may share the following categories of your CA Personal Information with third-party partners and customers in a manner that constitutes a “sale” under California law: Identifiers; Internet or other electronic network activity information; and Professional and other employment-related information. This information may be shared for the following purposes: to deliver customized advertising to you; providing data products and services to customers; developing new products and services; and performing services contracted by your employer or you.
  4. California Consumer Rights. Subject to certain exceptions, as a California resident, you have the right to: (i) request access to your CA Personal Information; (ii) request deletion of your CA Personal Information; (iii) request information about the CA Personal Information about you that we have “sold” (as such term is defined under California law) to third parties within the past 12 months; and (iv) opt-out of the “sale” or “sharing” of your CA Personal Information, as detailed above.
    • Do Not Sell/Share My Information. To opt-out of the “sale” or “sharing” of your CA Personal Information as described in this section, click on the “Do Not Sell My Information” link at the bottom of the screen.
    • Exercising other California consumer rights. Should you wish to request the exercise of your other rights as detailed above with regard to your CA Personal Information, we will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of products, based solely upon this request. Please see the “Contact Us” section below if you have questions or would like to exercise such rights.

CHANGES TO THIS PRIVACY POLICY

Except to the extent limited by applicable law, we reserve the right to update this Privacy Policy to reflect changes to our information practices by prominently posting notice of the update on our Sites. Unless otherwise noted, any updates will become effective 30 days after posting the updates to the Privacy Policy and apply to all information collected about you. If we make any changes to this Privacy Policy that materially impact previously collected information about you, we will, to the extent that we have your email address, notify you by email.

CONTACT US

If you have any questions about this Privacy Policy or information we have collected about you, or if you wish to exercise your California Consumer Rights as described above, please contact us by email at legal@npm.com or by postal mail at:

Nasdaq Private Market

Attn: Legal Department

3 E 28th St, 7th Floor,

New York, NY 10016