NASDAQ, INC., AND AFFILIATED COMPANIES PRIVACY POLICY

Effective Date: July 19, 2018

As a global financial services and technology provider and self-regulatory organization, Nasdaq is committed to protecting Personal Information and complying with applicable privacy requirements in a trustworthy, transparent and responsible manner. This commitment is shared by Nasdaq’s subsidiary, The NASDAQ Private Market, LLC.

This Privacy Policy describes how Nasdaq, Inc. and its subsidiaries and affiliates (collectively, “Nasdaq,” “we,” “our” or “us”) collects, uses and discloses Personal Information 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 or transaction platforms (each a “Site” or collectively, our “Sites”). As used in this Privacy Policy, Personal Information means any information relating to an identified or identifiable natural person; Personal Information is intended to cover all information subject to personal data processing and privacy laws applicable to our business. 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 Information processing and privacy via email at privacy@nasdaq.com and legal@npm.com.

In some instances, we may post or provide materials that provide further description of Personal Information processing related to certain products and services. We may also post information about how we comply with specific Personal Information laws or regulations like European Union or United States privacy laws. Such materials are for informational purposes only and are not intended as an exhaustive listing of Personal Information processing related to the product and service. The materials should not be construed as modifying this Privacy Policy.

Policy Overview:

Information About How This Policy Applies to our Global Company

  • Nasdaq has endeavored to develop a Privacy Policy that can be applied consistently across its global organization; however, certain elements are limited to situations where applicable law requires them. With respect to your Personal Information, the data controller will be the Nasdaq entity delivering products and service or with whom you are interacting. Click here to learn more.

Situations Where This Privacy Policy Does Not Apply

  • This Privacy Policy does not apply to the extent that other Personal Information processing or privacy terms are set forth in the applicable contract for Nasdaq’s products or services, posted on a Site or in certain other situations. Click here to learn more.

Information We Collect About You

  • We may collect Personal Information and Device Information (defined below) (collectively, “information”) about you in connection with your (or your employer’s) receipt of products or services including to fulfill our contractual obligations or establish or maintain a business relationship with us; your registration, use, purchase, or inquiries on or about our Sites that link to this Privacy Policy; the pursuit of our legitimate business interests; or, to comply with applicable law. Click here to learn more.

How We Use Your Information

  • We may use your information to provide services, respond to inquiries and provide customer support and technical assistance, communicate with you, process transactions, improve, develop, provide content for, operate, deliver and market our products, service or Sites, implement social networking features, comply with our company policies and procedures and with applicable law, ensure proper and authorized use of the Sites, perform Site tracking and analysis and as otherwise permitted by applicable law. Click here to learn more.

Automated Decision-making

  • No decisions that we make are based solely on automated decision making. Click here to learn more.

How We Share Your Information

  • We may share your information with our business units, affiliates, subsidiaries, business partners, customers/members, and service providers, your representatives, when we believe necessary to protect or enforce our rights or the rights of another user, and as otherwise permitted by law. We do not sell or share information with third parties so that they can independently market their own products or services to you, unless we have explicitly given you the option to opt-in such disclosures. Click here to learn more.

Your Rights Regarding Your Personal Information

  • We provide you with the opportunity to be informed of whether we are processing your information and, to the extent required under applicable law, to access, correct, update, oppose, delete, block, limit or object, upon request and free of charge, to our use of your Personal Information to the extent required by applicable law. Click here to learn more.

Security of Your Information

  • We maintain commercially-reasonable technical, administrative and physical security measures to protect your information. Click here to learn more.

International Transfers

  • We may transfer your information outside of your home country. To protect such information, any such international transfers will be made in accordance with applicable law. Click here to learn more.

Our Retention of Your Information

  • We retain your information to fulfill the purpose for which it was collected, comply with record retention requirements that apply to our business and where required to address legal or compliance matters affecting the information. Click here to learn more.

Cookies and Similar Technologies

  • We may use cookies and similar technologies to help deliver our products, services and Sites, offer you a more personalized user experience and market products and services to you. Click here to learn more.

Marketing Communications

  • You can opt out of receiving marketing communications from us. Click here to learn more.

Referrals

  • If you choose to refer an individual about our products or services, to explore a business relationship with us or to use our Sites, we will ask you for the individual’s name and email address for us to send your friend a one-time email to invite him/her to access the specific Site. Click here to learn more.

Links to Other Websites

  • Our Sites may contain links to other websites or services that are not owned or controlled by Nasdaq, including links to websites of our customers, service providers, advertisers, sponsors and partners. Click here to learn more.

Use of Sites by Children

  • Our Sites are not intended for use by children under the age of sixteen. Click here to learn more.

Changes to this Privacy Policy

  • You will be notified about any material changes to this Privacy Policy via a posting on our Sites, and as otherwise required by applicable law. Click here to learn more.

Contact Us

  • If you have questions about this Privacy Policy or wish to exercise your rights regarding Personal Information, please contact us at privacy@nasdaq.com or one of the other points of contact listed in this Privacy Policy. Click here to learn more.

 

Information about How this Policy Applies to our Global Company

As a global organization, different Nasdaq entities, products/services and Sites may be subject to different privacy laws based on where our entity operates, where the products/services are delivered and/or where you are located. For example, the European Union General Data Protection Regulation imposes certain requirements on some Nasdaq entities or services that are not applicable to all of our entities or services. Where this Privacy Policy states that a provision applies “to the extent required by applicable law,” such provision will be applicable only to the extent that Nasdaq is subject to legal requirements imposing it.

For purposes of data protection laws, except where this Privacy Policy does not apply, as described below, the Nasdaq entity that will be the “controller” of your Personal Information will be the entity that delivers the products or services you (or the company for whom you are working or have a business relationship) are receiving or maintains the Site that you are using. You can identify the Nasdaq company that hosts a particular Site through the Site’s footer or “About” link. A list of Nasdaq’s different business locations is available at this site: //business.nasdaq.com/discover/contact-us/index.html.

Although your data controller may be a specific Nasdaq entity, contact and other customer relationship information that we collect may be held in a customer relationship management or contact database which can be accessed by other Nasdaq entities which may be located globally; further information about international transfers of information is provided below.  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.

 

Situations where this Privacy Policy Does Not Apply

This Privacy Policy also does not apply to Personal Information processed in connection with delivery of services to Nasdaq by suppliers or contractors; such relationships are governed solely by the Personal Information processing terms and conditions between Nasdaq and the supplier/contractor. It also does not apply to job applicants or employees, which are subject to relevant privacy notices.

This Privacy Policy does not apply to the extent that:

  • Nasdaq’s contract for delivery of products or service prescribes different Personal Information terms and conditions for the processing of your information;
  • Nasdaq is delivering products or services as a data processor in which the contractual terms and conditions between Nasdaq and the controller/contracting party shall govern;
  • The Site for the products or services sets forth an additional or alternative Privacy Policy; or
  • Applicable law imposes different processing or privacy requirements on your information.

 

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 product or service or business relationship or communication involved consistent with the nature of such product, service or relationship 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 information (“Personal Information”) that you or your representative (such as your employer, financial services provider, legal representative, company where you are an officer, director or significant shareholder) provide to us:

  • Name;
  • Email address;
  • Social media username;
  • 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;
  • 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 (such as for security purposes when visiting our facilities); and
  • Any other Personal Information you or your representative volunteers on or provides access to via any or our Sites and/or any Nasdaq community forum, social media offering or blog.

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”):

  • IP address;
  • Device identifier;
  • Log files;
  • Cookies;
  • Clear gifs;
  • Flash LSOs; and
  • Other information as described in our Cookies Policy (Click here to view our Cookies Policy).

Certain Device Information may be deemed Personal Information in accordance with applicable law. Personal Information 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 Information 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;
  • 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 or 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 customer/subscribers; and
  • Other Personal Information 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 Nasdaq’s purposes for processing Personal Information. Often due to the nature of the product or service involved or the context in which the Personal Information 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 Information 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 on one or more of the following:

Purpose of Processing Bases for Processing
Provide you with our services and products and communicate with you about your account or use of our products, services and/or Sites ŸŸŸ+ Perform or enter into a contract
+ Legitimate business interest
+ 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, central shares depository, pension system administrator 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 Self-Regulatory Organization, 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
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 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 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 as a customer, business prospect and/or information recipient/td> + 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 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
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

With respect to situations where we process Personal Information based on our legitimate business interest, reflecting that we are generally a business-to-business product and service provider, we typically collect and process limited Personal Information about corporate customer points of contact and individuals acting in their professional capacities as part of our overall effect to reduce the privacy impact on individuals. 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.

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.

 

Automated Decision-Making

Nasdaq 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 Nasdaq’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 Information 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 Information in connection with your role with your employer or financial services provider), third party service providers and authorities in the following circumstances:

  • Nasdaq Business Units, 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. A list of Nasdaq’s offices by country is posted at: //business.nasdaq.com/discover/contact-us/index.html. 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 privacy@nasdaq.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, electronic records retention for regulatory purposes, electronic document signature and storage, identity verification / anti-money laundering / sanctions check providers, and product support ticket tracking, sending email marketing communications, or data analysis). 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, 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 Nasdaq or others, or to respond to emergencies.
  • 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 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 aggregate, 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 aggregate 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.

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 Information 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.

You always have right to request that we stop using your personal data for direct marketing purposes. 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. You also always have the right to withdraw your consent at any time when we need your consent in order to process your personal data. If you withdraw your consent, you will no longer receive information and offers that are tailored for you. Please see the section below for more information about your rights.

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 information for direct marketing and in certain other situations (in accordance with applicable law) by contacting us at privacy@nasdaq.com. If you are having difficulty unsubscribing from our email marketing communications using the above methods, please contact us as at privacy@nasdaq.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 Information

To the extent required by applicable law, in our capacity as the controller of your Personal Information, we will also provide you with the opportunity to be informed of whether we are processing your Personal Information and at any time to access, correct, update, oppose, delete, block, limit or object to our use of your Personal Information. 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 our registered broker-dealers – 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 your rights to the extent that your Personal Information is processed subject to the European General Data Protection Regulation:

  • 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 Information. You also have the right to request a copy of the Personal Information being processed at no cost. However, we may charge you a reasonable administrative fee to provide you with additional copies of the Personal Information. 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, anonymise, erase or complement Personal Information that you or we discover is inaccurate, incomplete or misleading. You also have the right to complete the Personal Information with additional data if relevant information is missing.
  • Erasure of your personal data. You have the right to request that we erase your Personal Information if we do no longer have an acceptable reason for processing the data. Given this, erasure shall be made by us if:
    • the Personal Information is no longer necessary for the purposes for which it was collected,
    • we use your Personal Information with your consent and you withdraw your consent,
    • you object to the processing of your Personal Information based on our legitimate interest and there is no overriding legitimate ground for the processing,
    • the Personal Information has not been lawfully processed,
    • we are required to erase the Personal Information due to a legal obligation, or
    • 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 prevents us from immediately erasing your Personal Information. In such case, we will stop using your Personal Information for any other reasons than to comply with the applicable law, or the relevant compelling reason.

  • Right to restrict processing: This means that we temporarily restrict the processing of your Personal Information. 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 Information to be erased,
    • as data controller, we no longer need the Personal Information for the purposes for which it was collected, but you require us to retain the information for the establishment, exercise or defence 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 Information 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 Information.

  • Right to object to processing. You have the right to object to the processing of your Personal Information 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 defence of a legal claim.
  • Right to portability. You have the right to receive certain of your Personal Information 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 or credentials 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, Nasdaq 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 //ec.europa.eu/justice/data-protection/international-transfers/transfer/index_en.htm). To the extent required or 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, legal or compliance matters related to the information.

 

Cookies and Similar Technologies

When you use our Sites, we along with our affiliates, subsidiaries and third party service providers may use “cookies” and similar technologies (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.

To learn more about the technology used on our Sites and how to disable some of the technology, visit our more comprehensive 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 Nasdaq, 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 Information 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.

 

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, please contact us by email at privacy@nasdaq.com or by postal mail at:

Office of General Counsel – Privacy Team

Nasdaq, Inc.
805 King Farm Blvd
First Floor
Rockville, MD 20850

With respect to Personal Information processing subject to European Union jurisdiction, in addition to contacting our business contacts and Data Protection Officer (for our EEA Regulated Businesses), you may also contact a data protection supervisory authority.

 

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The NASDAQ Private Market, LLC Global Cookie Statement

This Cookie Statement describes how Nasdaq, Inc. and its subsidiaries and affiliates (collectively, “Nasdaq,” “we,” “our,” or “us”) along with third party service providers may use “cookies” and similar technology (collectively, “technology”) on our websites, online features, products and services that link to this Cookie Statement (each a “Site” or collectively, “our Sites”). This technology involves placing small files/code on Your device or browser for the purposes identified in our Privacy Policy. By visiting or using our Sites, You are consenting to us gathering and processing information (as defined in our Privacy Policy) about You in accordance with this Cookie Statement.

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.

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 Nasdaq.

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, 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.

Changes to this Cookie Statement. Except to the extent limited by applicable law, we reserve the right to update this Cookie Statement to reflect changes to our information collection 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 Cookie Statement, and apply to all information collected about You. If we make any changes to this Cookie Statement that materially impact previously collected information about You, we will, to the extent that we have Your email address, notify You by email.