LAST UPDATED: JULY 18, 2024

Sylvanus Technologies, Inc. and its affiliates (collectively, “Sylvanus,” “we,” “us,” and “our”) provide platform services that include post-trade analysis, research, risk management, and portfolio management tools. This statement (“Privacy Policy”) is designed to help you understand how we collect, use, and share the personal information we collect from or about you when you use our websites and other services that include an authorized link or reference to this statement (“Services”), and to help you understand and exercise your privacy rights, where applicable. If your details are processed by us in the context of an agreement with you or the institution with which you are employed or affiliated, then the relevant data controller is the Sylvanus entity identified in the contract.

This Privacy Policy does not apply when Sylvanus is processing your personal information as a service provider to our customers. We obtain certain information about you to provide them with Services. Our customers operate independently from us, and your agreement with the relevant customer governs how they use and share your personal information, including with Sylvanus. Each customer’s privacy practices are subject to their privacy policies. If you have questions about a customer’s privacy policy, please direct those questions to the customer.

Data privacy is important to us. This Policy sets out how we collect, use and protect Personal Data (as defined below) which clients have provided to us depending on the interaction or engagement of our services. "Personal Data" refers to information including name, phone number, email address and contact details, and other personal information, that is being associated with an identified or reasonably identifiable individual.

Personal Information We Collect

Information You Provide to Us Directly. We may collect the following personal information that you provide to us:

Account Creation: We may collect information when you create an account with us, such as name, email address, phone number, business information such as company name and job title, and other sensitive information to conduct anti-money laundering and other required regulatory checks.
Usage Information: We may collect information related to your use of and interactions with our Services, such as your name, account information, and trade information such as amounts traded.
Financial Information: We may collect information such as your bank account details and billing address.
Your Communications with Us: We may collect personal information such as name, email address, phone number, or mailing address when you request information about our Services, request customer or technical support, or otherwise communicate with us.
Surveys: We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
Interactive Features: We and others who use our Services may collect personal information that you submit or make available through our interactive features (e.g., messaging and chat features, commenting functionalities, forums, blogs, and social media pages). Any information you provide on the public sections of these features will be considered “public,” unless otherwise required by applicable law, and is not subject to the privacy protections referenced herein.
Contact Information: We may collect personal information from individuals when we attend conferences, trade shows, and other events.

Information Collected Automatically. We may collect personal information automatically when you use our Services, including:

Automatic Data Collection: We may collect certain information automatically when you use our Services, such as your Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, mobile advertising and other unique identifiers, browser or device information, location information (including approximate location derived from IP address), and Internet service provider. We may also automatically collect information regarding your use of our Services, such as pages that you visit before, during and after using our Services, information about the links you click, the types of content you interact with, the frequency and duration of your activities, and other information about how you use our Services. When we send you emails, we may track whether you open them to learn how to deliver a better customer and user experience and improve the Services. In addition, we may collect information that other people provide about you when they use our Services.
Cookies, Pixel Tags/Web Beacons, and Other Technologies: Cookies are small text files placed on internet browsers that store information such as device type and configuration, preferences (e.g., language, time zone), and other information, to facilitate and enhance your online experience. A pixel tag (also known as a web beacon) is a piece of code embedded in our Services that collects information about engagement with our Services. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in emails to understand whether messages have been opened, acted on, or forwarded. We, as well as third parties that provide content, advertising, or other functionality on our Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through your use of our Services.

Our uses of these Technologies fall into the following general categories:

Operationally Necessary: This includes Technologies that allow you access to our Services, applications, and tools that are required to identify irregular website behavior, prevent fraudulent activity and improve security, or that allow you to make use of a particular functionality;
Performance-Related: We may use Technologies to assess the performance of our Services, including as part of our analytic practices to help us understand how individuals use our Services (see Analytics below);
Functionality-Related: We may use Technologies that allow us to offer you enhanced functionality when accessing or using our Services. This may include identifying you when you sign into our Services or keeping track of your specified preferences, interests, or past items viewed;
Advertisingor Targeting-Related: We may use first-party or third-party Technologies to deliver content, including ads relevant to your interests, on our Services or on third-party websites.
Analytics: We may use Technologies and other third-party tools to process analytics information on our Services, such as Google Analytics. For more information, please visit Google Analytics’ Privacy Policy.
Social Media Platforms: Our Services may contain social media plug-ins (that might include widgets such as the “share this” button or other interactive mini programs). These features may collect your IP address, which page you are visiting on our Services, and may set a cookie to enable the feature to function properly. Your interactions with these platforms are governed by the privacy policy of the company providing it.

Information Collected from Other Sources. We may obtain information about you from other sources, including your name and email address from our customers, in order to create an account for you.

If you do not provide certain information when requested, you may not be able to use the Services (or certain features or functionalities of the Services) if that information is necessary to provide you with the Services or if we are legally required to collect it.

How We Use Your Information.

We may collect and use your personal data for any or all of the following purposes:

To provide the Services: We may use your information to manage your information and accounts; provide access to certain areas, functionalities, and features of our Services; identify and authenticate access to our Services; process your transactions, and for other related purposes.
To perform obligations in connection with the provision of our Services: This includes verifying your identity, responding to your communications, managing your relationship with us, processing payments or handling transactions, and ensuring compliance with applicable laws and regulations.
To send you electronic correspondence: We may answer requests for customer or technical support and communicate with you about your account, activities on our Services, and policy changes.
To enable you to register for online or in-person events.
For any other purposes for which you have provided the information: This includes transmitting to unaffiliated third parties, including our third-party service providers and agents, and relevant governmental and regulatory authorities, whether in the U.S. or abroad, for the aforementioned purposes.
Any other incidental business purposes related to or in connection with the above.

Administrative Purposes. We use your information for various administrative purposes, such as:

To improve our Services: We may use your information for research and development (including marketing research), network and information security, and fraud prevention; to measure interest and engagement in our Services; to improve, upgrade or enhance our Services; and to develop new products and Services.
To keep the Services, business, customers, and users safe and secure: This includes detecting security incidents, protecting against malicious, deceptive, fraudulent or illegal activity, and prosecuting those responsible for that activity; ensuring internal quality control and safety; authenticating and verifying individual identities; debugging to identify and repair errors with our Services; and auditing relating to interactions, transactions and other compliance activities.
To comply with applicable laws and regulations: This includes, for example, meeting or complying with any applicable rules, laws, regulations, codes of practice or guidelines issued by any legal or regulatory bodies which are binding on us, or which we have been advised, recommended or informed that we are expected to comply with (including disclosures to regulatory bodies, conducting audit checks, surveillance and investigation, and due diligence), internal policies, assisting law enforcement or investigations by relevant authorities, and/or handling your information to protect or exercise our legal rights or defend against legal claims.

Marketing and Advertising our Products and Services. We may use personal information to tailor and provide you with content and advertisements. Subject to applicable laws and regulations, we may send direct marketing materials promoting services, products, through a variety of communication not limited to emails and newsletters, using information collected from or about you which we believe you may be interested in. Clients may opt-out of such communications at any time by unsubscribing to our services. Clients may also opt-out of such communications by following the directions provided in any marketing communication. It is our policy to not provide client’s Personal Information for those third parties’ direct marketing purposes without their consent.

How We Disclose Your Information

We may disclose your personal information to third parties for the purposes described in this Privacy Policy or as otherwise described to you at the time of collection, including:

Service Providers: We may disclose your personal information to our third-party service providers and agents that provide services to us, such as fraud prevention, identity verification, email delivery, auditing, marketing and advertising, analytics, website hosting, and data processing.
Business Partners: We may disclose personal information to our business partners who provide services or products to you.
Affiliates: We may disclose personal information to our affiliates, meaning an entity that controls, is controlled by, or is under common control with Sylvanus. Our affiliates may use the personal information we disclose to them for purposes consistent with this Privacy Policy.
Regulatory Bodies: We may disclose your personal information to regulatory bodies to comply with our legal obligations, applicable laws and regulations, requests from regulatory authorities, or to respond to subpoenas, court orders, or other legal processes.
Merger or Acquisition: We may disclose your personal information in connection with, or during negotiations of, any proposed or actual merger, purchase, sale, or any other type of acquisition, reorganization, or sale of some or all Sylvanus assets. Should such an event occur, we will use reasonable efforts to require that the new entity follow this Privacy Policy with respect to your personal information.

The purposes listed in the above clauses may continue to apply even in situations where your relationship with us (for example, pursuant to a contract) has been terminated or altered in any way, for a reasonable period thereafter (including, where applicable, a period to enable us to enforce our rights under a contract with the client).

Your Privacy Choices and Rights

You have certain rights and choices with respect to your personal information, including:

General Choices
1. Cookies and Interest-Based Advertising: You may be able to reject certain cookies, including the cookies associated with the Technologies we use to collect information about you for interest-based advertising. You may need to take additional steps to opt out of interest-based advertising from certain other third-party advertising networks. See our Cookie Policy for more details.
2. Marketing Communications: If you receive unwanted marketing communications from us, you can opt out by using the unsubscribe feature within the communication or by contacting us as described below. Even if you opt out of marketing emails, we may still send you non-marketing communications, such as emails about your account or Services you have requested.
3. Other Choices: You can also make choices about the collection, use, and sharing of your personal information, including adjusting your privacy settings in your account or contacting us directly as described below.

Your Privacy Rights

In accordance with applicable law, you may have the right to:

Access: You may have the right to access the personal information we maintain about you.

Correction: You may have the right to request that we correct your personal information.
Deletion: You may have the right to request that we delete your personal information.
Portability: You may have the right to request that we transfer your personal information to another organization, where feasible.
Objection: You may have the right to object to certain processing of your personal information.
Restriction: You may have the right to request that we restrict the processing of your personal information.
Withdrawal of Consent: Where we rely on your consent to process your personal information, you have the right to withdraw your consent at any time.

To exercise any of these rights, please contact us using the information provided below. We will respond to your request in accordance with applicable law.

Security of Your Information

To safeguard client’s personal data from unauthorized access, collection, use, disclosure, copying, modification, disposal, or similar risks, we have introduced appropriate administrative, physical and technical measures such as up-to-date antivirus protection, encryption, and the use of privacy filters to secure all storage and transmission of personal data by us, and disclosing personal data both internally and to our authorized third-party service providers and agents only on a need-to-know basis. Clients should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. While security cannot be guaranteed, we strive to protect the security of your information and are constantly reviewing and enhancing our information security measures.

Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

International Data Transfers

As a global business, personal data may be transferred to our subsidiaries and affiliates worldwide due to, for example, our shared infrastructure and collaborative tools we use globally. If you are accessing our Services from the European Economic Area (“EEA”), the United Kingdom, or Switzerland, please see the section below titled “European Data Privacy Rights” for additional information. When contracting with suppliers and/or transferring Personal Data to a different jurisdiction, we will take appropriate steps to ensure that your data is treated securely and the means of transfer provide adequate safeguards in accordance with applicable law.

Retention of Your Information

We retain your personal information for as long as necessary to provide you with the Services or for other important purposes, such as complying with legal obligations, resolving disputes, and enforcing our agreements. When we no longer need your personal information, we will securely delete or anonymize it in accordance with our data retention policies and applicable laws. We will also take reasonable steps to securely destroy or permanently de-identify your personally identifiable information when we no longer need it. Alternatively, the client may request to delete your personal information we have about them.

European Data Privacy Rights

If you are located in the EEA, the United Kingdom, or Switzerland, you have certain data privacy rights under applicable laws, including the right to lodge a complaint with a supervisory authority. If you are located in these regions and you have questions about your data privacy rights, please contact us as described below.

Children’s Privacy

Our Services are not intended for children under the age of 18, and we do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18 without verification of parental consent, we will take steps to delete that information from our records.

Third-Party Websites

Our Services may contain links to third-party websites or services. We are not responsible for the privacy practices or the content of those websites or services. Please review the privacy policies of any third-party websites or services before providing them with your personal information.

Updates to this Privacy Policy

We may update this Privacy Policy from time to time in response to changing legal, technical, or business developments. When we update our Privacy Policy, we will take appropriate measures to inform you, consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. You can see when this Privacy Policy was last updated by checking the “Last Updated” date displayed at the top of this Privacy Policy.