Privacy and Cookie Policy

TAPartnersLLC.net Privacy Policy

Effective as of November 7th, 2018

Purpose and Scope

TAPartnersLLC.net and each of its subsidiaries and affiliates, (collectively known as "TAPartners, LLC") are committed to safeguarding your personal information. We have adopted and implemented this privacy policy ("Policy") as part of our commitment to protecting your personal information across all of our services. We encourage you to read this Policy to learn more about the ways we collect, use, disclose, and protect your personal information.

Because we are a global company, this Policy takes into consideration various privacy regulations and frameworks for protecting the collection, use, maintenance, sharing, and disposition of personal information in compliance with applicable legal and regulatory requirements. Additional details relating to the European Union (EU) or, respectively, European Economic Area (EEA) (collectively, “EU/EEA”), United States, countries or other jurisdictions are provided in the body of this Policy as well as at the end of the Policy in the "Country- and State-Specific Notices" section.

Unless superseded by alternative Terms and Conditions (e.g. customer agreements, employee contracts) where appropriate, when you provide TAPartners, LLC with personal information, the method by which the information will be collected, used, distributed, and maintained will be in accordance with the terms outlined in this Policy.

By providing personal information and using our products and services you acknowledge the collection, use, distribution and maintenance of your personal information in the manner described in this Policy or the alternative Terms and Conditions under which the collection of the information applies. If you object to any aspect of this Policy or alternative Terms and Conditions, TAPartners, LLC asks that you do not submit your personal information or utilize our services.

Consent

Where required by law, we generally will seek your express written or oral consent for the collection, use, maintenance and distribution of your personal information.

There are situations where consent may not be sought as we are legally permitted under applicable laws to process personal information without consent. For example, depending on the applicable jurisdiction, this may include situations where;

the processing of personal information is required by law (e.g. subpoena);

the processing of personal information is required in order for TAPartners, LLC to fulfill its legal and regulatory obligations;

the processing of personal information is necessary as part of the provision and receipt of our products and services;

information is used in the aggregate to improve our products and services;

in response to an emergency or where the safety or health of an individual or the public is at risk; or

the information is publicly available.

Changes to the Privacy Policy

The Policy is current as of the effective date set forth above. The Policy is reviewed regularly and may change over time. All modifications are effective immediately, where permitted by law. Therefore, we encourage you to review this Policy periodically so you are aware of our practices. If we make material changes to the Policy by modifying our privacy practices that increase our rights to use personal information we have previously collected about you, we may attempt to notify you or obtain your consent, where required by law, either through your registered email address or by prominent posting on this page with an appended revision date.

Information Collection

TAPartners, LLC recognizes that personal information is considered to be any information relating to an identified or identifiable natural person. TAPartners, LLC may collect personal information directly from you and, in some circumstances, from those individuals and/or entities you may authorize to act on your behalf and, where permissible by applicable laws, from publicly available sources.

The type of information you may be requested to provide will vary based upon the type of relationship(s) you have established with TAPartners, LLC.

Most commonly, we collect your full name, professional job title, physical address, phone number, and your email address in order to provide you with services tailored to your particular needs. In connection with some of our products and services we may collect additional types of personal information including, but not limited to, full name, phone number, email, Internet Protocol (“IP”) address, Social Security Number, Financial Account Information, country of origin, etc. Please refer to the sections below or to the forms where we collect information from you for details.

TAPartners, LLC may collect personal information relevant to the purposes of administering its business, providing and improving its products and services, such as in relation to:

USE OF OUR WEBSITES ("SITES"): In order to better serve your particular needs, TAPartners, LLC (and third parties operating on TAPartners, LLC’s behalf) may collect information from or about you while visiting the Sites. Some of this information is collected automatically through cookies (see our Cookie Policy) and when using your log-in credentials. TAPartners, LLC may also obtain information directly from you and, depending upon the nature of transactions you may conduct, from third party sources.

From time to time, TAPartners, LLC may seek to collect input from you about the use of our Sites, products or services. This information may be collected with or without the collection of identifying information. If we request personal information, these fields will be optional, unless otherwise indicated, resulting in you having control over whether or not the answers remain anonymous. Third party tools may be used to facilitate these questionnaires.

We also collect non-personal (pseudonymized and anonymized) information when you visit TAPartners, LLC Sites. This information includes, but is not limited to, the pages you view, the search terms entered into the search utility, location, the operating system, browser software, preferred language and internet service provider you use. Such non-personal information we may collect generally is used to administer the Site, improve our services, determine how the Sites are being used, identify popular areas of the Sites, analyze trends and usage patterns, and offer you tailored content. If we associate your non-personal information with your personal information, we will generally treat everything as personal information.

Additionally, as permitted by law and regulation, your information may be used in aggregate, statistical form to track and measure usage including, but not limited to, customer/user preferences, interests, demographics, and patterns; and to determine trading volumes, audience size and repeated usage. We may then use such data, together with information collected from other users, to manage and customize the Site's content, layout, and our services in order to improve the Sites, enhance customer service, and provide tailored messages. We may combine personal information and non-personal information to conduct analytics in order to improve user experience.

We will use your IP address for legally permitted uses including to provide the services to you, to improve our services and to help diagnose problems with our server.

Furthermore, we may use the information you provide us to contact you about our products and services as legally permitted. Please see the section entitled "Contact Us" for instructions relating to opting out of such use.

The personal information you submit to us either via the Sites (e.g. by completing our on-line forms) or via email may be used to provide you with the response or services you have requested.

We do collect personal information about your online activities over time and across third party websites or online services. When we see a browser set to "do not track", signals transmitted from web browsers do not apply to our sites, and we do not alter any of our data collection and use practices upon receipt of such a signal.

TAPartners, LLC offers educational resources: including Algo App and TAP Institute (also known as Trading Analytics Institute) to increase the awareness of our industry. TAPartners, LLC collects information in aggregate for the Algo App and TAP Institute, and does not collect or maintain information that identifies any specific individual. The information collected is only used to improve upon functionality and its content.

The Sites may contain links to third party websites. Please note that when you click on one of these links, you will be accessing a website that TAPartners, LLC does not control and which may be governed by privacy policies and practices that differ from ours. TAPartners, LLC is not, and will not be, responsible for the privacy policies or practices of third parties or the content or security of any third-party websites.

PUBLIC FORUMS (e.g. website comment sections, Blogs, Social Media): Posts, comments or other information you submit on any public forums (e.g. message board, chat rooms) should not be considered private or confidential. TAPartners, LLC may use any such postings ("Postings"), any content thereof, and any information derived from any such Postings (including any ideas, concepts, know-how or other intellectual property) and may provide such Postings to any of its subsidiaries, affiliates, or others, for any purpose whatsoever, as deemed appropriate in the sole discretion of TAPartners, LLC and subject to applicable laws. Posts, comments, and other information you share on these platforms can be read, viewed, collected or used by others accessing these public forums. We have no responsibility for how others use the information you share on these public forums, such as sending you unsolicited communications, contacting you, or any other usage of your personal information. When registering, you may choose a username (pseudonym) that does not identify you to the general public.

TAPartners, LLC is under no obligation to review any Postings relating to TAPartners, LLC and assumes no responsibility or liability relating to any Postings. Nonetheless, TAPartners, LLC may from time to time monitor the Postings and in its sole discretion and in accordance with law may remove and/or decline to publish any material, including but not limited to: (i) any Postings that contain any unlawful, harmful, threatening, abusive, harassing, defamatory, vulgar, obscene, profane, hateful, racially, ethnically or otherwise objectionable material of any kind (ii) advertisements or solicitations of any kind; (iii) messages posted by visitors impersonating others; (iv) personal information, such as messages which list phone numbers, Social Security numbers, account numbers, addresses, or employer references; (v) messages by non-spokesperson employees of TAPartners, LLC purporting to speak on behalf of the TAPartners, LLC; (vi) multiple messages by the same visitor restating the same point; (vii) messages of commercial or reputational damage to TAPartners, LLC; and (viii) chain letters of any kind.

SOCIAL NETWORK ACCOUNT INFORMATION: We may allow you to sign into and associate your social network accounts including, but not limited to, Twitter, LinkedIn, Facebook, and YouTube with TAPartners, LLC.

By using this functionality, we deem that you consent by affirmative action to the use of your personal data for the purpose of enabling the functionality.

We may ask you to allow us to access certain elements of your social network profile information you have made available to be shared and to use it in accordance with the social network’s terms of use and this Policy. Each social network will give you full control over what kind of data you will share with us. Please refer to the privacy settings in your social network account for information about what data is shared and to manage the data shared through your account, including information about your activities using our Sites.

We do not retain your username or password for social networking platforms for any longer than is necessary to complete an interaction. If you would like to disconnect a social media account from TAPartners, LLC refer to the settings of that social media account and its provider.

EMAIL SUBSCRIPTIONS FOR NEWSLETTERS, NOTICES, AND SERVICE ANNOUNCEMENTS: If you have subscribed to receive communications from TAPartners, LLC (e.g., through the TAP Subscription Center), we may contact you by phone, text, mail or email, as applicable, related to company services, market or product announcements and newsletters, sales and marketing communications, and when applicable, service announcements pertaining to system maintenance or disruptions. Generally, you have the ability to opt-out of these marketing communications at any time by contacting us with the information in the “Contact Us” section of this Policy, clicking on the unsubscribe button located within the message, or directly modifying your preferences in the subscription center. Some non-promotional communications used for administrative purposes, such as service announcements, may be sent to you regardless of your status for receiving marketing communications.

SALES AND MARKETING AND CUSTOMER SERVICE: Based upon the TAPartners, LLC services you use, and as permitted by law, individuals from our sales and marketing and customer service teams may contact you directly by phone, email, mail or text messaging. Should you choose not to be contacted please submit a request to the Data Protection Officer ("Contact Us") or complete the form on "Unsubscribe – Email Alert Subscription." Unsubscribing from these communications may impact the way TAPartners, LLC may share information with you regarding the use of our services.

TAPartners, LLC may record certain telephone conversations, including phone lines in the Global Command Center, Clearing House, main switchboard, or where required by law. The purpose of such recordings is to provide verification of customer transactions entered in connection with TAPartners, LLC business, to protect the organization against misconduct, and to ensure the telephone lines are being used consistent with applicable TAPartners, LLC policies. When a recorded line is being used an announcement will be made at the beginning of the call notifying you that the call may be recorded and that you can object to such recording at the beginning of the call. Consent to such recording and monitoring is presumed by the use of the recorded phone lines without raising such objection. There may be instances where the recording cannot be turned off. Please use discretion when sharing information over a recorded line as the recording may be retained and used for legal, regulatory, or business purposes.

BILLING INFORMATION WHEN YOU ARE PURCHASING PRODUCTS OR SERVICES: There are certain circumstances for which TAPartners, LLC may collect personal information when you purchase products or services from us. For the purposes of these transactions, TAPartners, LLC may collect, use, and maintain personal information such as your name, email, phone number, and mailing address from you.

Where offered, you may choose to complete your transactions using credit or debit card information (e.g. Online Store, Software, Market Data). TAPartners, LLC does not directly process or retain any credit card information. Your credit card information will only be processed and stored with third parties that are Payment Card Industry Data Security Standard ("PCI DSS") compliant. The third parties are not allowed to share or use any of your information beyond the purposes for which it was collected. Where available, you may elect to have the third party maintain your credit card information for reoccurring purchases.

USE OF TAPartners, LLC TECHNOLOGY SYSTEMS: When using TAPartners, LLC systems, personal information may be collected and used to authenticate your access such as device type, operating system, browser, IP address, and country of origin. Additional information may be collected during your use of the technology so TAPartners, LLC can continue providing you the services applicable to the offering, and tailoring our content as appropriate. Refer to our Cookie Policy.

For registered users, upon the creation of your profile (by the user or at the request of your organization) personal information is required to be provided. Personal information collected will vary based on the type of relationship you have with TAPartners, LLC. Information collected may include, name, phone number (landline or mobile), email address, physical address, organization name, professional title.

Accessing TAPartners, LLC systems may require additional authentication credentials beyond a password. In these situations, you can request to receive the automated code via text message or telephone call. Receipt and use of this verification code may be required in order to gain access to certain TAPartners, LLC systems.

MEMBERSHIP: TAPartners, LLC may collect and use personal information for the purpose of processing membership applications. For the purposes of these applications TAPartners, LLC may collect, use, and maintain personal information such as your name, phone number, physical address, professional title, email address, social security number (or national identity number), date of birth, and place of birth. TAPartners, LLC does not share membership information with third parties except where required by law, or service providers. TAPartners, LLC distributes a weekly “Membership Bulletin” that is sent to all current members providing information on new, withdrawn or changed membership details on all membership sales.

MARKET DATA AGREEMENTS: TAPartners, LLC may collect personal information in order to comply with the provisions of agreements relating to receipt and/or use of market data. Under the provisions of such agreements, TAPartners, LLC will collect contact details for business and contact administration purposes. Such contact details may include name, title, phone number and email address. TAPartners, LLC will use this information for billing and business development management. TAPartners, LLC will use personal information submitted by licensees in order to supply, administer, manage and improve services provided by TAPartners, LLC and to comply with applicable regulatory and legal requirements.

RECRUITMENT AND EMPLOYMENT: TAPartners, LLC may collect personal information from applicants and potential candidates, employees, interns, temporary employees and consultants (collectively "Colleagues"), as part of recruitment and selection of candidates (e.g. resumes, contact details), to fulfill the terms of employment (e.g. references and background checks) and for staff administration purposes (e.g. payroll processing, providing benefits and performance reviews). Depending on the jurisdiction, we may process additional data as required or authorized by laws regarding taxes, social security and social protection, including sensitive information (special categories of personal data). We will separately inform you about this additional processing of personal data when you enter into an employment, internship, temporary employment or consulting agreement with us through the HR Privacy Policy applicable to the TAPartners, LLC entity.

Where necessary and permissible under applicable law, TAPartners, LLC may combine personal information from one service with information, including personal information, from other services or information that is publicly available to conduct due diligence for compliance and/or security purposes and/or to help us better understand your relationship to TAPartners, LLC to improve your experience. For further details, please refer to the applicable HR Privacy Policy.

CORPORATE TRANSACTIONS: TAPartners, LLC may collect personal information from third parties as part of a reorganisation, sale, merger or joint venture and will process it for the purposes of the business integration, including sending communications to you.

Location of Personal Information

TAPartners, LLC is a global company and may collect and process personal information in countries throughout the world. Therefore, subject to applicable laws, your personal information may be located and used in a country where TAPartners, LLC does business other than your country of residence or where you provided TAPartners, LLC with your personal information. These other countries may not have the same data protection laws as the country in which you reside. When we transfer your information to other countries, we protect that information as described in this Policy. By submitting your information, you acknowledge our collection, transfer, and processing of your personal information in accordance with this Policy.

Third Party Access to Information

We do not share personal information with third parties, unless one of the following conditions applies:

We have obtained your consent to share your personal information.

To disclose information about the use of our websites or mobile applications but only in aggregate, statistical form.

To protect TAPartners, LLC’s rights, property or safety of its assets and Colleagues and where permitted by law.

To assist with investigations into malicious or fraudulent activity or other potential security or compliance threats or violations.

To support auditing, compliance, and corporate governance functions.

To cooperate fully with state, local, federal, and international legal, governmental and regulatory entities, authorities and officials in any investigation or governmental, legal or regulatory proceeding relating to any information collected or to any purported unlawful activities.

As permitted by law, the information we collect, including personal information, may also be disclosed to third parties if TAPartners, LLC, in its sole discretion, believes disclosure is necessary to comply with legal or regulatory processes or requests or to protect the rights, property, or personal safety of TAPartners, LLC, its affiliates, and/or the respective customers, members, directors, officers, employees and agents and/or the public.

To enforce our Terms and Conditions.

If TAPartners, LLC or any of its assets are acquired by a third party, in which case personal information may be one of the transferred assets.

When we share access to personal information with companies or individuals working on TAPartners, LLC’s behalf, we protect such personal information by requiring those parties to enter into agreements (e.g., non-disclosure agreements) with TAPartners, LLC to safeguard the confidentiality of personal information, to use the personal information only for TAPartners, LLC purposes, and ensure compliance with applicable data protection laws.

Retention of Personal Information

TAPartners, LLC retains personal information for the duration of the business relationship or where required, in accordance with the corporate Records and Information Management Policy and Retention Schedule. We make reasonable attempts to ensure that all instances of such information (e.g. production, backups, etc.) are deleted in their entirety, including any of your personal information. For requests for access, corrections, or deletion please see "Contact Us".

Children's Privacy

The Sites are general audience sites not directed at children under the age of 13. If we obtain actual knowledge that any personal information we collect has been provided by a child under the age of 13, we will promptly delete that information. If you access our Sites from the EU/EEA or if you access an EU/EEA Site, the age limit will be 16.

TAPartners, LLC does offer a website and a mobile application for students to learn more about our industry. Please refer to the discussions of Algo App and TAP Institute within this Policy for more information under the header "Use of Our Websites".

Further, we occasionally allow children to be onsite for work experience/job shadowing. As a result, personal information (such as name, contact details and parent/guardian) may be processed to administer access to relevant TAPartners, LLC facilities and while such individuals are onsite (see TAPartners, LLC Facilities and Visitors section below).

Monitoring of Electronic Communication

TAPartners, LLC reserves the right to monitor all electronic communications that occur on TAPartners, LLC information systems where a TAPartners, LLC representative is party to the communication as deemed necessary and appropriate, subject to applicable law. TAPartners, LLC generally does not monitor the content of messages offered directly to our customers via Pivot and TAP Direct where a TAPartners, LLC representative is not an active participant within the communication. For more information regarding electronic communications with TAPartners, LLC, please click here.

Security

TAPartners, LLC takes security and the protection of your personal information seriously. We have implemented a physical and logical security program that includes commercially reasonable administrative, physical, and technical safeguards. These controls may be updated as new technology and controls become available, or as appropriate.

To safeguard TAPartners, LLC facilities and colleagues, TAPartners, LLC may collect personal information and video when you are on company premises. Your personal information may be used for security and due diligence purposes. TAPartners, LLC uses video recording in public areas of its facilities, 24/7. We will clearly post signs indicating such video surveillance and/or recording on site.

Access to or Deletion of Your Information

You may request from us certain information about you including, but not limited to, any information you have provided to us upon registration for various services. TAPartners, LLC will provide individuals with access to their personal information, allow modifications, or request deletion, within reason and in accordance with applicable laws. We are committed to keeping your personal information current and accurate. If your contact information should change, please "Contact Us" so that we may update our records accordingly.

Prior to fulfilling any request for information or deletion, we may require you to provide information so we may verify your identity. Subject to applicable laws, we reserve the right to decline requests that are unreasonable, present risk to the privacy of another individual, may jeopardize the confidentiality of another party, are excessively repetitive, or may require significant technical modifications to our systems. Provided the request is reasonable in nature, all requests for information will be free of charge. TAPartners, LLC reserves the right to respond to any requests as soon as reasonably possible, but generally within 30 days or one month, whichever is shorter. For Korean residents, TAPartners, LLC will respond to any such requests within 10 days.

Requests should be sent to Privacy@tapartnersllc.net.

Contact Us

All complaints, questions or comments regarding TAPartners, LLC’s Policy should be directed to Privacy@tapartnersllc.net. If you wish to opt out of receiving communications from TAPartners, LLC or others as described in this Policy, please contact TAP at Privacy@tapartnersllc.net. All questions and comments will be directed to the Privacy Office.

TAPartnersLLC.net

104 Water Street

Wilmington, DE 19804

1.312.928.9287

1.866.928.9287 (US Only)

privacy@tapartnersllc.net

Related Notices:

Confidentiality and Data Protection Policy

News and Events Alerts Subscription & Unsubscribe Email Alert Subscription

Disclaimer: www.tapartnersllc.net

Cookie Policy

Country - and State - Specific Notices

The notice for “European Customers (EU/EEA)” below applies to:

Any activities in the context of an establishment or subsidiary of TAPartners, LLC in the European Union (EU) or other countries in the European Economic Area (EEA) (collectively, “EU/EEA”); and

visits to our Sites or use of TAPartners, LLC systems by natural persons located in and from the EU/EEA; and

the offering of products or services to natural persons located in the EU/EEA, irrespective of whether a payment of the data subject is required; and

any monitoring of the behaviour of natural persons as far as such behaviour takes place within the EU/EEA.

EU currently consists of the Member States Austria, Belgium, Bulgaria, Croatia, Cyprus, Czech Republic, Czechoslovakia, Denmark, Estonia, Finland, France, Germany, Greece, Hungary, Ireland, Italy, Latvia, Lithuania, Luxembourg, Malta, Netherlands, Poland, Portugal, Romania, Slovenia, Spain, Sweden, United Kingdom; the EEA additionally includes Iceland, Liechtenstein and Norway.

The other following notices apply to customers who are residents of the specific country or state mentioned.

European Customers (EU/EEA)

We will process your data in accordance with Regulation (EU) 2016/679 (General Data Protection Regulation) (“GDPR”). Additional information regarding the processing of your personal data as required by the GDPR is set out in the following sub-sections.

Data Controller: The entity responsible for the processing of personal data (data controller) is, in the following order or precedence:

for the processing of personal data in the context of visits to our Site at tapartnersllc.net: TAPartnersLLC.net as identified in the section “Contact Us” above; for visits to other Sites or access to other TAPartners, LLC systems, the TAPartners, LLC entity identified on such website or system;

for the processing of personal data of Colleagues, the TAPartners, LLC entity identified in the employment, internship, temporary employment or consulting agreement or, respectively, the job posting;

for activities in the context of the sale and/or procurement of products and services, the TAPartners, LLC entity identified in the order form, agreement, or applicable Terms and Conditions; and

the TAPartners, LLC entity identified in the location where we make reference to this Policy, such as a form where we collect personal data, email signatures, business cards, stationary, etc.

In each case, this Policy should be read as “TAPartners, LLC” or “we” being a reference to the respective data controller as identified above.

List of cookies we collect

The table below lists the cookies we collect and what information they store.

COOKIE nameCOOKIE Description
CART The association with your shopping cart.
CATEGORY_INFO Stores the category info on the page, that allows to display pages more quickly.
COMPARE The items that you have in the Compare Products list.
CURRENCY Your preferred currency
CUSTOMER An encrypted version of your customer id with the store.
CUSTOMER_AUTH An indicator if you are currently logged into the store.
CUSTOMER_INFO An encrypted version of the customer group you belong to.
CUSTOMER_SEGMENT_IDS Stores the Customer Segment ID
EXTERNAL_NO_CACHE A flag, which indicates whether caching is disabled or not.
FRONTEND You sesssion ID on the server.
GUEST-VIEW Allows guests to edit their orders.
LAST_CATEGORY The last category you visited.
LAST_PRODUCT The most recent product you have viewed.
NEWMESSAGE Indicates whether a new message has been received.
NO_CACHE Indicates whether it is allowed to use cache.
PERSISTENT_SHOPPING_CART A link to information about your cart and viewing history if you have asked the site.
POLL The ID of any polls you have recently voted in.
POLLN Information on what polls you have voted on.
RECENTLYCOMPARED The items that you have recently compared.
STF Information on products you have emailed to friends.
STORE The store view or language you have selected.
USER_ALLOWED_SAVE_COOKIE Indicates whether a customer allowed to use cookies.
VIEWED_PRODUCT_IDS The products that you have recently viewed.
WISHLIST An encrypted list of products added to your Wishlist.
WISHLIST_CNT The number of items in your Wishlist.