Privacy Policy

Last Updated:  May 26, 2016

This Privacy Policy or “Policy” explains how Genesis Global Trading. (“Genesis”, “we”, “our”, and “us”), a division of SecondMarket, Inc., a broker-dealer registered under Section 15 of the Sercurities Exchange Act of 1934, as amended, and a member of the Financial Industry Regulatory Authority (FINRA), collect and protect Personal Information (as defined below). If you have any questions that this Policy does not address, please contact us at [email protected] By creating an account on the Genesis Trading Site or by otherwise submitting Personal Information to us through the Genesis Trading Site, you give your consent to the collection and use of your Personal Information as explained in this Policy. This Policy is part of our Terms of Service  and all capitalized terms used but not defined in this Policy have the meaning given to them in the Terms of Service.

 

Genesis’ Policy applies to current and former Genesis clients and any other users of the Genesis Trading Site. The term “Personal Information” refers to non-public information that personally relates to or identifies you as an individual or entity.

 

Updates and Changes to Our Privacy Policy

 

Please note that, in the event of a change in policy, a revised Policy will promptly be posted to the Genesis Trading Site. You agree to accept posting of a revised Policy electronically on the Genesis Trading Site as actual notice to you. Any dispute over our Policy is subject to this notice.

 

How and Why We Gather Information

 

When you sign up to participate on a Genesis Trading Site, you may be asked to provide information such as your full legal name, address and date of birth, along with other personal information that is required to verify your identity and fulfill our legal and regulatory requirements. This information will also be used to transact your business and communicate with you. From time to time, we may request additional information to help us further assess your needs and preferences.

 

Types of Information We Collect

 

The information we collect and maintain about you is provided during the course of your entering into transactions with private issuers who have engaged Genesis to provide certain services in the context of a private securities, digital currency or other financial asset transaction or trading through Genesis. This Personal Information, not available publicly, comes from the following sources:

 

Information you provide to us when you fill out account opening documents, complete a form or make a request for services, including your name, address, age, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and liabilities and/or income details and confidential documentation used to verify those details, telephone number, e-mail address and similar information; and

Information from your transactions with us, such as your sale proceeds or investment amount.

How We Protect Your Information

 

Keeping Information Safe

 

We limit access to the Personal Information you provide us to those employees who need access to that information in order to provide you with services related to the transactions you are entering into through the Genesis Trading Site. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards, and controls designed to protect your Personal Information.

 

We have invested in software, systems and procedures aimed at offering you a safe and secure transaction environment and protect your personal, financial and historical transaction information. While no security system is absolutely impenetrable, we plan to constantly review, refine and upgrade our security technology as new tools become available.

 

The Importance of Being Accurate

 

We have security standards and procedures in place designed to prevent unauthorized access to your Personal Information. A key part of this process helps ensure that the Personal Information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately. We only use your Personal Information as appropriate to provide you with quality services and to ensure security. For example, we may use the information collected from you to verify your identity and contact information. We may also use this information to establish and set up your trading account and maintain your trading information. This information helps us improve our services to you.

 

An Ongoing Commitment to Your Privacy

 

We are just as committed to protecting the privacy of our former clients as we are our current clients. If you choose to become an inactive client, your Personal Information will continue to be protected by the privacy policies and principles described in the then-current version of this Policy. Should you close your account with us, Genesis will retain your information for regulatory compliance, internal record-keeping and other legal purposes.

 

How Information Helps Both You and Us

 

Information about you and your accounts plays a key role in our ability to service our clients and administer our business. For example, we use information about you to:

 

Respond more accurately and efficiently to your requests for assistance; and

Secure your accounts and help protect you and Genesis from fraud.

Sharing Your Information with Unaffiliated Third Parties

 

We Limit the Sharing of Information

 

To protect your privacy, we limit the sharing of your Personal Information outside of Genesis. We conduct our business with great respect for the confidential nature of the information being provided. We will not share Personal Information about you except as outlined below:

 

To help us provide our services to you and/or to improve our services, we engage qualified and reputable third parties to help us to carry out certain functions such as account processing, client services and/or data collection relevant to our business. For example, in each case where you enter into a financial transaction through the Genesis Trading Site, we share your Personal Information with third party service providers in order to perform regulatory-required background checks, with certain technology providers to facilitate document execution, and with third parties that perform transaction execution and clearing services on your behalf. Pursuant to our agreements with these service providers, their ability to use your Personal Information is specifically limited to the service being provided.

To the extent that you upload Personal Information and sign transactional documentation via the Genesis Trading Site in connection with a securities, financial asset or other transaction, we may share your Personal Information and the documentation that you execute with the parties with which you are transacting.

As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution or similar event, Personal Information may be part of the transferred assets.

Genesis may share information with our affiliates if the information is required to provide the services you request. An affiliate is a company that we own or control, or with which there is common ownership with us.

Genesis also reserves the right to disclose your personal information where required by law to regulatory, law enforcement or other government authorities, including during routine regulatory examinations. We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.

Reviewing, Changing or Correcting Information

 

You are responsible for helping us to maintain the accuracy and completeness of your Personal Information and other data. We urge you to review your information regularly to ensure that it is correct and complete. If you would like to review your Personal Information or if you believe that any of your Personal Information is incorrect, or if you have any questions regarding your Personal Information, or this Privacy Policy, please contact us at [email protected]

 

Third Party Sites

 

If at any time you choose to purchase a product or service offered by another company, any Personal Information you share with that company will by subject to the privacy policies of the applicable third party company and will not be controlled by our Privacy Policy. Other than as described above, we are not responsible for the privacy policies or the content of third party sites and/or services (each, a “Third Party Service”) we link to, and have no control of the use or protection of information provided by you or collected by those Third Party Services. Whenever you elect to hyperlink to a Third Party Service, you may be asked to provide registration or other information. Please note that the information you are providing is going to a third party and you should familiarize yourself with the privacy policy provided by that party.

 

Privacy and the Internet

 

The following additional information will be of interest to you if you access a Genesis Trading Site and/or one of its affiliates’ products or services through one or more of our websites:

 

Users of the Genesis Trading Site are required to identify and authenticate themselves prior to accessing our services. Generally, identification and authentication take place through the use of your user name and a password.

The Genesis Trading Site is built upon an infrastructure with multiple layers of protection, including physical security of our equipment to system intrusion detection capabilities. Within such site, we use industry standard encryption technologies to help safeguard your information.

Security is a cooperative effort between us and the users of the Genesis Trading Site. Please remember that your user identification and password are personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them.

“Cookies” are small text files that may be placed on your web browser when you visit our websites. Cookies make it easier for you to navigate our website by, among other things, “remembering” your identity so that you do not have to input your password multiple times as you navigate between our website pages and/or access our services. Authentication (i.e., verifying that you are who you say you are) is an essential component of site security. You can set your web browser to inform you when cookies are set, or to prevent cookies from being set. Please note that if you decline to use cookies, you may experience reduced functionality, slower site response times, and declining to use our authentication-related cookies may prevent you from using our website altogether.

Web surfing data (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences) may be collected by Genesis, or by our service providers. This may be accomplished by using cookies, Web beacons, page tags or similar tools that are set when you visit our website. Web surfing data and similar information may be shared internally within Genesis and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our websites; and as otherwise permitted by applicable law or regulation. If you are a Genesis client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by Third Party Services, solely in accordance with our instructions.

The Genesis Trading Site may include social media features (“Features”), such as the Facebook Like button and widgets, such as the “Share This” button or interactive mini-programs that run on this Site (“Widgets”). These Features and Widgets may collect your IP address, which page you are visiting on a Genesis Trading Site, and may set a cookie to enable the Feature or Widget to function properly. Social media Features and Widgets are either hosted by a third party or hosted directly on a Genesis Trading Site. Your interactions with these Features and Widgets are governed by the privacy policy of the company providing it.

CalOPPA Disclosures

 

Do Not Track Signal

 

We do not currently respond to web browsers’ “Do Not Track” signals that provide a method to opt out of the collection information about visitors’ activities on the Genesis Trading Sites, and across other websites. If we do so in the future, we will provide all relevant information in this Privacy Policy.

 

Third Party Data Collection

 

We may authorize certain third parties, including, without limitation, Google Analytics, Chartbeat and Mixpanel, to track usage and collect information about users and their activities on the Genesis Trading Sites.

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