Privacy Policy
Updated August 15, 2025
This Privacy Policy describes how Nasdaq Private Market, LLC (located 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 ( “user(s)” or “you”) receiving our products and services, exploring or maintaining a business relationship with us (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 consent to us collecting and processing information about you in accordance with this Privacy Policy. We may process your Personal Data based on the specific legal bases outlined the section below entitled “How We Use Your Information”. Where we require your consent for specific processing activities (e.g., marketing communications, non-essential cookies), we will request it through a clear, affirmative action (like ticking a box or clicking a button), and you may withdraw your consent at any time for processing of these activities in the future.
The Privacy Policy also describes your applicable rights 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 any 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, and passport or other government-issued identification information (for identity verification purposes);
- 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;
- and
- Any other information that you or your representative voluntarily provides on our Sites, blogs, or similar forums. If we request such information, we will indicate at the point of collection the purpose for which we are requesting it.
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”, which in some instances may also be considered Personal Data; Personal Data and Device Information are collectively referred to as “information.”):
- Internet Protocol (IP) address;
- Device identifier;
- Geolocation;
- 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.
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, 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 purposes and applicable bases:
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 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 in accordance with 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 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
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 as otherwise 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 sections 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 by contacting us as described in this Privacy Policy.
AUTOMATED DECISION MAKING
NPM does not engage decision making based solely on automated processing which produces legal effects concerning any individual or similarly significantly affects any individual.
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. 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. To opt-out of such sharing based on consent, 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 require these third parties to maintain appropriate security to protect your information from unauthorized access or processing. We do not authorize these third parties to use your information for any purposes other than the specific purpose(s) for which it has been provided, and do not permission these third parties to disclose that information to any unauthorized parties.
- As Required or Appropriate by Law. We may disclose your information to regulatory authorities, 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 process and share aggregated or otherwise de-identified information with other parties. For example, we may utilize survey information collected from you on an aggregated or otherwise not individually identifiable basis. We also use aggregated or de-identified information for other 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 you, or any particular client or user, and will not be used by any 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: (1) you can use 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). If you are having difficulty unsubscribing from our email marketing communications using the above methods or otherwise wish to object to certain usage, please contact us as at legal@npm.com.
We will make reasonable efforts to comply with your request as soon as reasonably practicable and 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 still 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 considering 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.
In general and depending on applicable laws, you have the following rights with respect to our processing of your Personal Data:
- 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 to the extent: (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, or (v) we are required to erase the Personal Data due to a legal obligation.
However, there might be requirements under applicable law or other 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 other reason.
- 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 of the third parties with which we have shared your Personal Data (if any).
- 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 relevant 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. If we transfer Personal Data outside of its country of origin, we have implemented controls designed to ensure that such transfers are lawful and that your data remains protected by appropriate cross-border transfer solutions to provide adequate protection for transfers of certain personal information, including 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 your information as described above.
RETENTION OF YOUR INFORMATION
We will retain your Personal Data only as long as reasonably necessary for the purpose(s) for which it was collected. The criteria used to determine our retention periods include:
- The duration of our relationship with you or the company you represent;
- The length of time necessary to provide the services you have requested;
- Our legal and regulatory obligations, including recordkeeping requirements under securities laws (e.g., typically 7 years for transactional data); and
- Any potential need to resolve disputes or enforce agreements.
Personal Data collected for marketing purposes is retained until you withdraw your consent. If you want additional information about retention periods for your Personal Data, please contact us as described herein.
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” and similar technologies or others 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, including remembering your preferences (e.g., language) and generally improving your experience on our Sites. For example, we may use such technology to:
- Provide us with general analytics about our Sites, including demographic information in a de-identified 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 you or your personal 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:
- Networking Advertising Initiative (http://www.networkadvertising.org/choices/) (US Only)
- Digital Advertising Alliance (http://www.aboutads.info/choices/) (US Only)
- European Interactive Digital Advertising Alliance (http://www.youronlinechoices.eu/) (EU Only)
- Digital Advertising Alliance – Canada (http://youradchoices.ca/choices) (Canada Only)
- DAA App Choices Mobile App (Mobile Devices Only) – For mobile devices (e.g., smartphone, tablets), you may consider downloading the DAA AppChoices Mobile App to manage such technology.
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 from 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 any such tracking information outside of NPM.
Flash LSOs. Flash Local Storage Objects (“Flash LSOs” or “Flash Cookies”) display content based upon your preferences for how you like to view our Sites. Flash LSOs are different from browser cookies in relation to the size, types, and storage of collected information. 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 section and the Privacy Policy generally.
REFERRALS
If you choose to use our referral service to tell someone about our products or services or Sites, we will ask you for that person’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 or from 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
To ensure compliance with the California Consumer Privacy Act (CCPA) and the California Privacy Rights Act (CPRA), NPM provides the following disclosure regarding the collection, use, and sharing of personal information of California residents.
Categories of Personal Information Collected, Purposes of Collection and Use, and Sharing Practices:
| Category of Personal Information | Purpose of Collection and Use | Categories of Third Parties with Whom Information is Shared |
| Identifiers (e.g., name, email address, postal address, phone number) | To provide and manage our products and services. To communicate with you regarding your account or transactions. To send promotional communications, where permitted by law. | Service providers assisting in operations (e.g., IT support, customer service). Affiliates and subsidiaries for business purposes. Legal authorities when required by law. |
| Commercial Information (e.g., records of products or services purchased, obtained, or considered) | To personalize your experience with our services. To understand and analyze usage trends and preferences. | Service providers for analytics and marketing assistance. Affiliates for business optimization. |
| Internet or Other Electronic Network Activity Information (e.g., browsing history, search history, interaction with our website) | To improve our website functionality and user experience. To conduct analytics on site usage and performance. | Third-party analytics providers. Marketing partners for targeted advertising. |
| Professional or Employment-Related Information (e.g., job title, employer). | To verify your identity and eligibility for certain services. To comply with legal and regulatory obligations. | Compliance and regulatory bodies. Service providers conducting background checks, where applicable. |
| Legal and Regulatory Information (e.g., eligibility to participate in financial markets, sanctions status, background screening results, fraud or law enforcement risk indicators) | To assess eligibility to participate in NPM services. To conduct anti-money laundering (AML) and sanctions screening. To manage regulatory and legal compliance risks. | Internal use by authorized personnel only. Government regulators or enforcement bodies, as required. |
| Audio or Visual Information (e.g., recorded voice where notified, photograph) | For identification, security, and training purposes. To document communications where permitted or required. | Internal use by authorized personnel only. |
Retention Periods:
NPM retains personal information for as long as necessary to fulfill the purposes outlined above, comply with legal obligations, resolve disputes, and enforce our agreements. The specific retention period depends on the nature of the information and legal requirements.
California Consumer Rights:
Subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:
| Right to Delete | You can request that we delete personal information we have collected about you. |
| Right to Correct | You can request corrections to inaccurate personal information held by us, based on the nature and purpose of the data. |
| Right to Know What Personal Information is Being Collected | You have the right to know what personal information we collect, including: 1. The categories of personal information collected; 2. The categories of sources of the personal information; 3. The purposes for which the personal information were collected; 4. The categories of personal information disclosed to third parties (if any), and the categories of recipients to whom the personal information were disclosed; 5. The specific pieces of personal information collected; 6. The categories of personal information shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the personal information were disclosed for those purposes; and 7. The categories of personal information sold (if any), and the categories of third parties to whom the personal information were sold. |
| Right to Know What Personal Information is Sold or Shared and to Whom | You can request details about the sale or sharing of your personal information, including categories of data and recipients. |
| Right to Opt Out of Sale or Sharing of Personal Information | You may direct us not to sell or share your personal information with third parties. |
| Right to Limit Use and Disclosure of Sensitive Personal Information | You can limit how your sensitive personal information (like financial or health data) is used or disclosed. |
| Right to Access & Portability | You have the right to access the personal information we have collected about you. Where required by law, you can also obtain a copy of that information in a portable, technically feasible, and readily usable format that allows you to transmit it to another entity without hindrance. |
| Right of No Retaliation | We do not discriminate against any person for exercising applicable privacy rights. However we reserve the right to change the applicable terms of the service when you have exercised your rights, provided the change(s) are reasonably related to the value provided to us by Your data. |
Exercising Your Rights:
To exercise any of these rights, please contact us via email at legal@npm.com. We will verify your identity before processing your request to protect your privacy and security.
Note: This disclosure is provided in accordance with the CCPA and CPRA requirements and reflects NPM’s commitment to transparency and the protection of your personal information.
US Consumer Privacy Notice
The following Consumer Privacy Notice applies to you if you are an individual who resides in the United States and uses NPM services for your own personal, family, or household purposes.
| FACTS | WHAT DOES NPM DO WITH YOUR PERSONAL INFORMATION? |
| Why? | Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. |
| What? | The types of personal information we collect and share depend on the product or service you have with us. This information can include: Social Security number and account balances Payment and/ or transaction history When you are no longer our customer, we continue to share your information as described in this notice. |
| How? | All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons NPM chooses to share; and whether you can limit this sharing. |
| Reasons we can share your personal information | Does NPM share? | Can you limit this sharing? |
| For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus | Yes | No |
| For our marketing purposes – to offer our products and services to you | Yes | No |
| For joint marketing with other financial companies | Yes | No |
| For our affiliates’ everyday business purposes – information about your transactions and experiences | Yes | No |
| For our affiliates’ everyday business purposes – information about your creditworthiness | No | We don’t share |
| For our affiliates to market to you | Yes | Yes |
| For nonaffiliates to market to you | Yes for NPM services only | Yes for NPM services only. We don’t share for all other products |
| Questions? | Contact us at legal@npm.com. |
| To limit our sharing | |
| To limit our sharing | You may limit our sharing by contacting us as described in this Privacy Policy. |
| Who we are | |
| Who is providing this Privacy Statement? | This privacy notice is provided by Nasdaq Private Market, LLC on behalf of it and its Affiliates, and is applicable to your personal U.S. NPM accounts. |
| What we do | |
| How does NPM protect my personal information? | To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and buildings. |
| How does NPM collect my personal information? | We collect your personal information, for example, when you open an account or provide account information. We may also collect your personal information from others, such as credit bureaus, affiliates, or other companies. |
| Why can’t I limit all sharing? | Federal law gives you the right to limit only sharing for affiliates’ everyday business purposes — information about your creditworthiness affiliates from using your information to market to you sharing for nonaffiliates to market to you State laws and individual companies may give you additional rights to limit sharing. See below for more information on your rights under state law. |
| Definitions | |
| Affiliates | Companies related by common ownership or control. They can be financial and nonfinancial companies. Our affiliates include NPM Securities, LLC and SecondMarket Financial, LLC. |
| Nonaffiliates | Companies not related by common ownership or control. They can be financial and nonfinancial companies. Nonaffiliates with which we share personal information include service providers that perform services or functions on our behalf. |
| Joint Marketing | A formal agreement between nonaffiliated financial companies that together market financial products or services to you. Our joint marketing partners include financial companies and banks. |
| Other important information | |
| We may transfer Personal Information to other countries, for example, for customer service or to process transactions. California: The California Consumer Privacy Act of 2018 (CCPA) permits consumers who are California residents to ask businesses covered under the CCPA about Personal Information it has collected about the consumer, submit an access or deletion request, and opt-out of the sale of Personal Information, if applicable. These provisions do not apply to personal information collected, processed, shared, or disclosed by financial institutions pursuant to federal law such as the Gramm-Leach-Bliley Act. Please see our “For California Consumers” notice for more information. Contact us if you have questions about our privacy statement, this consumer notice, or your Personal Information. If your NPM account or profile has a California mailing address, we will not share Personal Information we collect about you except to the extent permitted under California law. Vermont: If your NPM account or profile has a Vermont mailing address, we will not disclose information about your creditworthiness to our affiliates and will not disclose your personal information, financial information, credit report, or health information to nonaffiliated third parties to market to you, other than as permitted by Vermont law, unless you authorize us to make those disclosures. Nevada: If your NPM account or profile has a Nevada mailing address, we are providing this notice pursuant to Nevada law. If you prefer not to receive marketing calls from NPM, contact us at legal@npm.com with “Nevada Marketing Notice” in the subject line. | |
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 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 any of your rights, including 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 (Privacy)
3 E 28th St, 7th Floor,
New York, NY 10016