MARKETS EQ PRIVACY POLICY

Last modified October 1, 2024

ATTENTION: PLEASE READ CAREFULLY THIS MARKETS EQ PRIVACY POLICY ("PRIVACY POLICY"), WHICH IS PART OF THE MARKETS EQ TERMS OF USE BEFORE YOU ACCESS, DOWNLOAD, OR OTHERWISE USE THE SERVICE.

The Service is operated by Markets EQ, Inc., 169 Madison Ave STE 2652, New York, NY 10016 (“We,” "MARKETS EQ"). This Privacy Policy describes the information collected through Your use of the Service, how We use it, how We share it, how We protect it, and the choices You can make about Your information.

ATTENTION: PLEASE READ OUR PRIVACY POLICY CAREFULLY BEFORE USING THE SERVICE. USING THE SERVICE INDICATES THAT YOU ACCEPT AND AGREE TO BE BOUND BY THIS PRIVACY POLICY IN FULL. IF YOU DO NOT ACCEPT THIS PRIVACY POLICY, DO NOT USE THE SERVICE. You acknowledge (a) that You have read and understood this Privacy Policy; and (b) for users outside the European Union, this Privacy Policy shall have the same force and effect as a signed agreement.

Unless explicitly stated otherwise, any new features that augment or enhance the current Service shall be subject to this Privacy Policy.

This Privacy Policy is part of the MARKETS EQ TOU Any terms defined in the TOU shall have the same meaning in this Privacy Policy.

We will make updates to this privacy policy from time to time. Please review the Privacy Policy each time You use the Service. BY USING THE SERVICE, YOU AGREE TO BE BOUND BY THE MOST RECENT VERSION OF THE PRIVACY POLICY.

1. Information We Collect

We collect information from You when You use the Service, contact or interact with us, sign up for our newsletter or other mailing list, apply for employment with us, and voluntarily provide us with Your comments and other content in connection with using the Service.

As part of your access to and use of the Service, we may collect: Your name, contact information including email address, telephone number, address, information included in employment applications, and any other information you voluntarily provide on the Service.

When You contact us, we may collect: Your name, contact information including email address, telephone number, and any other information that You voluntarily provide to us.

When You access and use the Service, we automatically collect information regarding You and Your device, including Your device’s Internet Protocol address, the domain name of Your Internet service provider, your location, Your mobile device information (e.g. device model and operating system version), your page visits, and aggregated information that cannot be used to specifically identify You. Additional information collected is described in the Analytics and Cookies sections below.

We may collect information about You from third party sources. The Service provides links to our Twitter, Instagram, and LinkedIn pages. If You connect with these websites through the Service, We may receive personal information about You.

We may combine all of the information we collect from or about you and use it in the manner described in this Privacy Policy.

2. How We Use Your Information

We use the information that We collect for several purposes, including:

• The purposes for which You provided it;
• To provide information and services to You;
• To conduct analysis of language samples submitted to the Service;
• To process and respond to Your inquiries and comments;
• To send You information about Your relationship with us or about new projects or other information that we think you may find interesting;
• To contact you for market research purposes and to use this information to customize the Service according to your interests;
• To administer, operate, and improve the Service or to further the mission of MARKETS EQ;
• To personalize and enhance Your experience using the Service;
• To send periodic emails. If you choose, the email address You provide may be used to send You occasional news, updates, related product or service information, etc. Note: If at any time You would like to unsubscribe from receiving future emails, We include detailed unsubscribe instructions at the bottom of each email;
• To generate and review reports and data about our user base and Service usage patterns;
• To analyze the accuracy, effectiveness, usability or popularity of the Service;
• To compile aggregate data for internal and external business purposes;
• To prevent fraud and abuse of the Service and to otherwise protect users and visitors and our business;
• To assist law enforcement and respond to subpoenas; and
• To perform other business activities as needed, or as described elsewhere in this Privacy Policy.
• As explained elsewhere in this Privacy Policy, personal information We collect may be processed by our partners in providing services related to the Service (such as administration services, technical services relating to the maintenance, servicing, and upgrading of software, hosting services, customer service, data migration services, payment processing services and analytical services, among others).
Legal Bases for Using Personal Information

Performance of a contract

The use of your personal information may be necessary to perform the agreement you have with us to provide products and services. For example, to complete Your account registration or to provide ongoing assistance with Your account.

Legitimate interests

We may use your personal information for our legitimate interests. For example, We rely on our legitimate interest to analyze and improve our Services and the content on our website, to send you notifications about our Services, or to use your personal information for administrative, fraud detection, or legal purposes

Consent

Prior to accessing this site and providing your personal data, You may have provided Your informed consent to the collection and use of certain personal data. You are free to withdraw your consent at any time, subject to the "Your Choices Regarding Your Information" section below and the preceding Legal Bases for Using Personal Information in this Section.

Compliance with legal obligations

We may use your personal information to comply with legal obligations to which we are subject including to comply with legal processes.

3. How Your Information is Disclosed

Information may be disclosed to third parties in accordance with our Privacy Policy. Please note that a user may choose not to share certain information as described in Your Choices Regarding Your Information below

1. Third Party Service Providers and Business Partners.We may use third party service providers and business partners to perform functions in connection with the Service, such as email marketing, site analytics, social sharing, relationship management, functions related to analyzing and improving the Service usefulness, reliability, user experience, and operation, storing data, and as otherwise described in this Privacy Policy. We also may share Your personal information with these providers and partners for their direct marketing and promotional purposes and so they can provide services to you.
• X (formerly Twitter) By clicking on the X button on the Service, You will automatically be transported to the official X feed of MARKETS EQ, https://twitter.com/Markets_EQ.
• Linkedin. By clicking on the Linkedin button on the Service, You will automatically be transported to the official Linkedin Page of MARKETS EQ, https://www.linkedin.com/company/markets-eq/
• Mixpanel. We use Mixpanel to evaluate our vistors' behavior on the Service and to gather feedback related to user experience on the Service. Mixpanel may collect heatmap analytics information, browser information, other hardware information, Your IP address, and other behavioral indicators on the Service. For more information, please visit Mixpanel's privacy policy at: https://www.mixpanel.com/legal/privacy-policy.
• LLMs. When you submit language samples for analysis on the Titanium version of the Service, we may use certain large language models (collectively “LLMs”) to process such samples. All information transmitted to the LLMs will be kept in a separate, logically-separated environment from any other data the LLMs processes for other customers and will not be used for any training of LLMs.
2. Payment Processing. Any payment information You provide through the Services may be shared with and may be stored by our payment processor, Stripe, and is subject to its privacy policy, including in the case of a data breach. You may review Stripe's privacy policy at https://stripe.com/privacy.
3. Business Changes. If We become involved in a merger, acquisition, sale of assets, joint venture, securities offering, bankruptcy, reorganization, liquidation, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, We may transfer Your information to a third party or parties in connection therewith.
4. Affiliates. We may also share Your information with our affiliates for purposes consistent with this Privacy Policy. Our affiliates will be required to maintain that information in accordance with this Privacy Policy.
5. Investigations and Law. We may disclose information about You to third parties if We believe that such disclosure is necessary to:
   • Comply with the law or guidance and cooperate with government or law enforcement officials or private parties;
   • Investigate, prevent or take action regarding suspected illegal activities, suspected fraud, the rights, reputation, safety, and property of us, users or others, or violations of our policies or other agreements with us;
   • Respond to claims and legal process (for example, subpoenas); and/or
   • Protect against legal liability.
6. Aggregated Information. We may share aggregated information relating to users of the Service with affiliated or unaffiliated third parties. This aggregated information does not contain personal information about any user.
7. Analytics. We use third-party analytics tools to better understand who is using the Service and how people are using it. These tools may use cookies and other technologies to collect information about Your use of the Service and Your preferences and activities. These tools collect information sent by Your device or the Service and other information that assists us in improving the Service. This information may be used to analyze and track data, determine the popularity of certain content, and better understand Your online activity, among other things.
8. Cookies and Other Tracking Technologies

We, along with third parties, use cookies, local storage objects, Web beacons and other technologies. These technologies are used for personalization, optimization, tracking, and analytics of the Service.

Cookies are small files that are transferred to and stored on Your computer through Your Web browser (if You allow it) that enable the website’s or service provider’s system to recognize Your browser and capture and remember certain information. You can instruct Your browser to stop accepting cookies. But if You do not accept cookies, You may not be able to use all portions of all functionality of the Service.

• Persistent cookies remain on the visitor’s computer after the browser has been closed.
• Session cookies exist only during a visitor’s online session and disappear from the visitor’s computer when they close the browser software.

Flash cookies (also known as local shared objects) are data files that can be created on your computer by the websites you visit and are a way for websites to store information for later use. Flash cookies are stored in different parts of your computer from ordinary browser cookies. You can disable the storage of flash cookies. For additional information about managing and disabling flash cookies, please visit http://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html..

Web beacons are small strings of code that provide a method for delivering a graphic image on a Web page or in an email message for the purpose of transferring data. You can disable the ability of Web beacons to capture information by blocking cookies.

We use cookies and other tracking technologies on the website to help us understand and save Your preferences and interests so We can personalize Your future visits and compile aggregate data about website traffic and website interaction so that We can offer better website experiences and tools both now in the future.

Some of our business partners, such as our analytics providers also use cookies and other tracking technologies on our website, some of which may track users across websites and over time.

4. Security

We implement a variety of security measures to protect the safety of Your personal information when You enter, submit, or access Your personal information.

While We take reasonable measures to protect the information You submit via the Service against loss, theft and unauthorized use, disclosure, or modification, We cannot guarantee its absolute security. No Internet, email, or mobile application transmission is ever fully secure or error free. Email or other messages sent through the Service may not be secure. You should use caution whenever submitting information through the Service and take special care in deciding with which information You provide us.

We cannot guarantee that transmissions of Your personal information will be fully secure and that third parties will never be able to defeat our security measures or the security measures of our partners. WE ASSUME NO LIABILITY FOR DISCLOSURE OF YOUR INFORMATION DUE TO TRANSMISSION ERRORS, THIRD PARTY ACCESS, OR CAUSES BEYOND OUR CONTROL.

Any information collected through the Service is stored and processed in the United States. If you use our Service outside of the United States, you consent to have your data transferred to the United States.

5. Data Retention Policy, Managing Your Information

We will retain Your information for as long as You use the Service and for a reasonable time thereafter. We may maintain anonymized or aggregated data, including usage data, for analytics purposes. We may retain and use Your information as necessary to comply with our legal obligations, resolve disputes, and/or for the period required by laws in applicable jurisdictions. Please note that some or all of the information We have collected may be required for the Service to function properly.

6. Links to Other Websites or Applications

This Privacy Policy applies only to the Service. The Service may contain links to other websites or apps or may forward users to other websites or apps that We may not own or operate and to which this Privacy Policy does not apply. The links from the Service do not imply that We endorse or have reviewed these websites or apps. The policies and procedures We describe here do not apply to these websites or apps. We neither can control nor are responsible for the privacy practices or content of these websites or apps. We suggest contacting these websites or app providers directly for information on their privacy policies. Nonetheless, we seek to protect the integrity of our Service, and welcome any feedback about these linked websites and mobile applications.

7. Your Choices Regarding Your Information

You have choices regarding the use of information by the Service.

• Changing Your Information– To change Your information, You may log in to Your account’s control panel and go to the settings page. If You are unable to log into Your account, please contact us at info@marketseq.ai.
• Closing Your Account- You may close Your account by contacting us atinfo@marketseq.ai. If the email account associated with Your email address is not active, We may close Your account without notice.
• Withdrawing Consent- EU Data Subjects who have provided consent for processing may choose to withdraw Your consent to Our processing of Your information and Your use of the Services at any time by requesting that Your personal information be deleted, except for information required to be retained as provided for in our Privacy Policy. This deletion is permanent and Your information cannot be reinstated. To proceed with this request, please emailinfo@marketseq.ai.
8. EU Privacy Rights

Users based in the European Union have the following legal rights in respect of their information:

• The right to require MARKETS EQ to confirm whether or not their information is being processed, the purpose of any such processing, the recipients of any information that has been disclosed, the period for which their information is to be stored and whether any automated decision-making processes are used in relation to their information;
• The right to require MARKETS EQ to rectify inaccurate information without undue delay;
• The right to request the erasure of their information. Subject to certain conditions, MARKETS EQ may be required to erase the information in response to such request where:
  • the information is no longer necessary in relation to the purpose for which it was collected, such as where a user chooses to terminate his or her use of the Service;
  • the processing of the information is based on the user’s consent (and the other circumstances described in the ‘Legal Basis for Processing Your information’ and ‘How Your information Is Disclosed’ sections above no longer apply), if the user withdraws his or her consent; or
  • the user objects to the processing of his or her information and there are no overriding legitimate grounds for the processing.
• Where MARKETS EQ has disclosed the information of a European Union user to a third party and the user requests the erasure or rectification of the data, MARKETS EQ will take all reasonable steps to inform the third party of such request.
• The right to restrict MARKETS EQ from processing their information in certain circumstances, such as where the accuracy of that information is disputed or an objection has been raised (see below). In such circumstances, MARKETS EQ will only process that information with the express consent of the user, or for the establishment, exercise or defense of legal claims or for the protection of the rights of another natural or legal person or for reasons of important public interest;
• The right to receive their information from MARKETS EQ in a structured, commonly used and machine-readable format;
• The right to object to the processing of their information by MARKETS EQ where:
  • MARKETS EQ has relied on the ‘legitimate interest’ basis for processing that information, in which case we will immediately stop processing the user’s information unless we have compelling legitimate grounds which override the interests, rights and freedoms of the user; or
  • the information is used for direct marketing purposes, in which case we will immediately stop processing the user’s information for such purposes.
• The right to lodge a complaint with the data protection supervisory authority of the EU member state where the user resides.
• The above legal rights are subject to various conditions and exceptions including where the data is used for statistical or scientific research purposes and the exercise of the right would prevent such purposes from being attained or would seriously impair their attainment.
9. Information Collected From Other Websites and Mobile Applications and Do Not Track Policy

Your browser or device may offer You a “Do Not Track” option, which allows You to signal to operators of websites, web applications, mobile applications and services (including behavioral advertising services) that You do not wish such operators to track certain of Your online activities over time and/or across different websites or applications. Our Service does not support Do Not Track requests at this time, which means that We or our analytics providers or other third parties with which We are working my collect information about Your online activity both during and after Your use of the Service.

10. Children

Our Service is not intended for children under 13 years of age. We do not knowingly collect personal information from an individual under age 13. If You are under the age of 13, please do not submit any personal information through the Service. If You have reason to believe that We may have accidentally received personal information from an individual under age 13, please contact us immediately at info@marketseq.ai.

11. Changes to Privacy Policy

We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this Privacy Policy periodically, and especially before You provide any information. This Privacy Policy was made effective on the date indicated above.

12. How to Contact Us

Please feel free to contact us by email at info@marketseq.ai or by writing us at MARKETS EQ, LLC, 169 Madison Ave STE 2652, New York, NY 10016, if You have any questions about this Privacy Policy.

13. Nevada Privacy Rights

The Nevada Revised Statutes (NRS 603A.300 et seq.) permit a Nevada consumer to direct an operator of an Internet website or online service to refrain from making any sale of any covered information the operator has collected or will collect about that consumer. A Nevada consumer may submit a request pursuant to this directive by emailing us at info@marketseq.ai. We will provide further information about how We verify the authenticity of the request and the requestor’s identity.

14. Your California Privacy Rights

Section 1798.83 of the California Civil Code permits California residents to request from a business, with whom the California resident has an established business relationship, certain information about the types of personal information the business has shared with third parties for those third parties’ direct marketing purposes and the names and addresses of the third parties with whom the business has shared such information during the immediately preceding calendar year. You may make one request each year by emailing us at info@marketseq.ai or by writing us at MARKETS EQ, LLC, 169 Madison Ave STE 2652, New York, NY 10016.

Privacy Policy Supplement for California Residents

We do not sell personal information. You will not need to create an account to exercise Your rights. California residents have the right to:

• Right to Know. You have the right to ask MARKETS EQ to disclose to you (i) the categories of personal information, (ii) the categories of sources from which the personal information is collected, (iii) the business or commercial purpose for collecting, selling, or sharing personal information, (iv) the categories of third parties to whom we disclose personal information, and (v) a copy of the specific pieces of personal information we have collected about you (see below).
• Right to Access. You have a right to ask MARKETS EQ to provide you with a copy of the specific pieces of personal information that we retain about you, where feasible in a readily usable electronic format.
• Right to Correct. Subject to certain conditions and exceptions, that we correct inaccurate personal information that we maintain about you, taking into account the nature and purposes of the processing of the personal information.
• Right to Deletion. You have the right to ask MARKETS EQ to delete personal information it has collected about you. The Right to Deletion may, subject to applicable law, not apply in certain circumstances, for example when MARKETS EQ needs the personal information: (i) to complete a transaction with you, provide a good or service requested by you, or otherwise perform a contract with you; (ii) to detect or prevent security incidents or illegal activity; (iii) to identify and correct errors that impair existing functionality; (iv) for the exercise of a legal right or to ensure another person can exercise his or her legal right; (v) to comply with applicable legal requirements; (vi) solely for internal uses that are reasonably aligned with expectations based on your relationship with MARKETS EQ; (vii) to comply with a legal obligation; or (viii) for lawful internal uses that are compatible with the context in which MARKETS EQ obtained the information.
• Right to Limit Use and Disclosure. Subject to certain conditions and exceptions, you have the right to limit the use and disclosure of sensitive personal information (as defined under applicable local laws). However, as stated above, we do not use or disclose your sensitive personal information for purposes except as described herein (and as permitted pursuant to applicable law, including where applicable the CCPA).
• Right to Non-Discrimination. The right not to be subject to discriminatory treatment for exercising rights under the applicable privacy laws.
• Right to Opt-Out. Subject to applicable laws, the right to opt out of certain types of processing, including:
  • to opt out of the “sale” (as such term is defined under applicable law) of your personal information.
  • to opt out of targeted advertising by us (or for California users: to opt out of “sharing” (as defined under CCPA) of your personal information).
  • to opt out of any processing of personal information for purposes of making decisions that produce legal or similarly significant effects.
• Right to Appeal. If we deny your privacy rights request, you may, depending on applicable law, also appeal our decision by submitting your appeal to info@marketseq.ai.
• Marketing communications. You can opt out of receiving direct marketing emails from us at any time by using the unsubscribe link in the footer of each marketing email we send to you.

To exercise these rights, You may email us at info@marketseq.ai.

Before We can fulfill the consumer requests noted above, We must verify Your identity. The process will differ depending on the website in relation to which You are submitting Your request.

Verification Process

We will require You to provide us with Your name, telephone number, and email address, together with a signed declaration under penalty of perjury that You are the consumer whose personal information is the subject of the request. We will match this information to the personal information We maintain.

You can also authorize another person, called an agent, to exercise Your rights on Your behalf. You must provide the authorized agent written and signed permission to act on Your behalf. We may deny requests from an authorized agent who does not submit proof that he or she has been authorized to act on Your behalf. Furthermore, We may require You to verify Your identity directly with us. We may also require You to directly confirm with us that You have provided the authorized agent permission to submit a request on Your behalf. An authorized agent can make a request on Your behalf by emailing us atinfo@marketseq.ai.

We may not discriminate against You because You exercised any of Your rights under the CCPA, including, but not limited to, by:

1. Denying goods or services to You.
2. Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
3. Providing a different level or quality of goods or services to You.
4. Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services.

To the extent that anything in this Supplement for California Residents conflicts with the Policy, this Supplement for California Residents shall govern.