Privacy Policy

 

Definitions

'User'

Any employee of a financial institution which has engaged with Market76 as a third party software provider.

'Client'

Any person to whom a User may be advising financially or to whose financial data a User has legal access.

'The Site'

Includes any and all "Market76" or "Persona" branded applications produced by Market76 and and all pages contained within.

Information We Collect

Market76, Inc. collects certain personally identifiable financial information about its Users and their Clients to ensure that it provides the highest quality financial networking tools. The personally identifiable financial information which we gather during the normal course of doing business and in particular with User interaction with the site may include, but is not limited to:

  • Information users enter into our database. This information includes but is not limited to geographic or investment goal information related to clients.

  • Information about transactions and positions.

  • Information collected through an Internet "cookie" (an information collecting device from a web server).

  • Information on user behavior like interaction with pages within the Site.

Information We Disclose

Market76 does not disclose non-public, personal Client information. Unless prohibited by the originating 3rd-party data vendor, Market76 may use information provided by User to Market76, directly or indirectly through a 3rd-party vendor, regarding User behavior or anonymous, aggregated Client information for the purpose of providing improved services to User. In those allowed cases, Market76 may make non-personally identifiable aggregates and summaries of data available to:

  • Advertisers and other third parties for their marketing and promotional purposes;

  • Organizations approved by Market76 that conduct research into consumer financial decision making;

  • Users of the Service for purposes of benchmarking to community aggregates.

Such information does not include any non-public personal Client information. Access to any personal information is strictly restricted and used in accordance with internal security procedures. We may also use third party vendors or service providers to help us provide the Service to you, such as hosting a particular feature or functionality of the Service. Our contracts with these third parties outline the appropriate use and handling of your information and prohibit them from using any of your personal information for purposes unrelated to the product or service they provide.

Additional Restrictions Related to Data From Specific Vendors:

Limits on Market76’s use of data synced from Google services (Gmail, Calendar, etc): Notwithstanding anything else in this Privacy Policy, if Users provide Market76 access to the following types of their Google data, the App's use of that data will be subject to these additional restrictions:

  • Market76 will only use access to read, Gmail message bodies (including attachments), metadata, headers, and settings to provide Users with the ability to view this information in context of Market76 application. Market76 will not transfer this Gmail data to others unless doing so is necessary to provide and improve these features, comply with applicable law, or as part of a merger, acquisition, or sale of assets.

  • Market76 will not use this Gmail data for serving advertisements.

  • Market76 will not allow humans to read this data unless we have your affirmative agreement for specific messages, doing so is necessary for security purposes such as investigating abuse, to comply with applicable law, or for Market76’s internal operations and even then only when the data have been aggregated and anonymized.

Confidentiality and Security

Market76 follows industry standards in protecting and safeguarding nonpublic personal information. All data is stored in an SSAE16 compliant facility. We restrict access to nonpublic personal information about Clients and Users to those employees who need to know that information to provide financial products or services to you. We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your nonpublic personal information.

Security Practices

For full information on our security practices, please make a request to security@market76.com.