Last updated on: August 22, 2024 at 22:09 UTC
This Policy applies to personal data we collect both online and offline, including personal data we collect through our customer portal and public-facing websites (collectively the “Sites”) in connection with products and services we offer to you or the entity you represent (together with the Sites, the “Services”), and any other interactions you may have with us including at or through conferences, events, electronic newsletters or communications, or job postings and applications. In this Policy, “personal data” means any information that identifies, relates to, describes, is reasonably capable of being associated with or reasonably can be used to identify an individual or household and other data that is linked to personal data or is otherwise defined as “personal data,” “personal information,” or “personally identifiable information” by applicable laws. You have choices when it comes to the use of our Services and the data you share. When we ask you to provide personal data, you can decline. Our products and services may require some personal data to provide you with the service or access to a service. If you choose not to provide data required to provide you with a product or feature, you cannot use that product or feature. Similarly, where personal data collection is necessary to enter into or carry out a contract with you, and you do not provide the data, we will not be able to enter into the contract; or, if this relates to an existing product or service, we may have to cancel or suspend it.
We may modify this Policy from time to time. If we make changes, we will revise the “Last Updated” date at the top of the Policy on our Sites and, where necessary or required, use reasonable efforts to provide you additional notification by sending you an email. We encourage you to review this Policy regularly to stay informed of our privacy practices and the choices available to you.
The personal data we collect about you depends on how you interact with us. We describe below the categories of personal data we collect and the sources of this information.
We collect personal data from you when you visit our Sites, including accessing our customer portal, sending us an email, filling out a form, subscribing to our newsletter, responding to a survey or job posting, interacting with us on social media, or otherwise communicating with us. Types of personal data we may collect include:
We and our service providers may automatically log personal data about you, your computer or mobile device, and your interaction over time with us, such as:
We may also collect personal data about you from other sources, including publicly available databases, and combine that with information we collect from you and through your use of the Services. For example, we may use information from LinkedIn to update information about you in our contact database and we may use a third party to recruit talent to fill any of our employment opportunities. In addition, as part of our due diligence practices, we may collect personal data about you from records databases, including civil and criminal court records, government sanctions lists such as those maintained by the Office of Foreign Assets Control and the European External Action Service, business filings, and public media articles. In some cases, we may also collect information about you provided by others, such as an administrator for your company’s account who provides information about other personnel at your company.
We may derive information or draw inferences about you based on the personal data we collect or have otherwise received about you. For example, we may infer your approximate location based on your IP address, or that you are interested in participating in an event based on your browsing behavior on our Sites or response to our social media posts.
Depending on how you interact with us, we may use your personal data to:
We may disclose your personal data with the entities listed below or as otherwise described in this Policy:
We may also disclose aggregated, anonymized, or de-identified information, which cannot reasonably be used to identify you. We do not share your personal data with third parties for those third parties’ direct marketing purposes.
We implement appropriate physical, technical and administrative measures to help protect personal data from unauthorized access or use. If you have questions about the security of the personal data we collect, please contact us using the information provided below.
What are cookies? A cookie is a small file containing a string of characters that is sent to your computer when you visit a website or use an online service. When you visit the website or use the online service again, the cookie allows that website or online service to recognize your browser or device. Cookies may store unique identifiers, user preferences and other information. The type of cookies we may use include:
Why do we use them?We use cookies to collect information about you so we can provide the experiences you request, recognize your visit, track your interactions, improve your experience and detect and prevent fraud. How do you control cookies? Web browsers allow some control of most cookies through the browser settings. Most mobile devices also offer settings to reject mobile device identifiers. Although users are not required to accept cookies or mobile device identifiers, blocking or rejecting them may prevent access to, or impair the functionality of, some features available through our Sites. To find out more about cookies, including how to manage and delete cookies, visit www.aboutads.info/choices. You can also opt-out of interest based advertising from participating members by visiting http://www.networkadvertising.org/choices/. For individuals in the EEA, please visit www.youronlinechoices.eu and for individuals in Canada, please visit https://youradchoices.ca. Where required by applicable law, we obtain your consent prior to placing or using optional cookies that are not (i) strictly necessary to the functioning of the Sites; or (ii) for the purpose of facilitating a communication. Third-Party Services We May Use: We use web analytics services like Google Analytics and advertising platforms to help us operate our Services and provide marketing and advertising to you. You can find out more about how Google uses your personal data by visiting www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout (opens in a new tab). Do Not Track: Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Occasionally, at our discretion, we may include links to other websites. The privacy practices of these third parties will be governed by the parties’ own privacy notices. We are not responsible for the security or privacy of any information collected by these third parties, and disclaim all responsibility and liability for the content, services, and activities of such third parties. You should review the privacy notices or policies applicable to these third party products and/or services. Some aspects of our website may allow you to interface with social media services such as Facebook, LinkedIn, and X (formerly known as Twitter®). By using these interfaces, you allow us to access information about you from those social media services, including information and other content that you submit to those social media services. For a description on how such social media services and other third-party platforms, plug-ins, integrations, and applications handle your information, please refer to their respective privacy policies and terms of use, which may permit you to modify your privacy settings with that service or platform.
We may retain your personal data in compliance with applicable law for as long as is necessary to fulfill the purpose for which this data was collected and for the business purposes explained in this Policy. We may retain your personal data in some instances to:
In cases where we keep personal data, we do so in accordance with any limitation periods and records retention obligations that are imposed by applicable law.
Consistent with applicable law, you may exercise the rights described in this section. Please note that the rights may vary depending on your country or state of residence. Please see the Region Specific Terms section below. To exercise your privacy rights please contact us as listed below. While it is our policy to respect the rights of individuals under applicable law, please be aware that your exercise of these rights is subject to certain exemptions and exceptions. For example, some of these rights might be limited (e.g., the right to withdraw consent) where we are required or permitted by law to continue processing your personal data to deliver services to you, defend our rights or meet our legal and regulatory obligations. If you contact us to exercise any of these rights, please note that we only implement requests with respect to the personal data associated with you as an individual. We may need to verify your identity before implementing your request and will try to comply with your request as soon as reasonably practicable and in accordance with the timelines required under applicable law. If we cannot verify your identity or your ownership rights to the data, we may not be able to service your request until you provide proper documentation.
You may opt out of receiving direct marketing communications from us by following the unsubscribe instructions contained within the communication, or if you or your organization are a current subscriber to our Services, by changing your account settings through the customer portal. Please note that there are certain communications we are required to send you that you may not be able to opt out of (e.g., support and important legal notices). If you are receiving communications from us as part of a larger corporate email group within your own organization (e.g., info@abccorp.com), we will not have control over your individual personal data and will not be able to process your request.
You may have the right to request access to, and receive details about, the personal data we maintain about you and how we process it, correct inaccuracies, or request that we delete your personal data by contacting us as indicated below. If you or the organization you represent are a subscriber to our Services, you can also sign into the customer portal and update any of your personal data stored in the customer portal.
Where you have provided your consent for us to use your personal data, subject to applicable law, you have the right to withdraw your consent and we will apply that preference going forward.
In certain circumstances depending on your jurisdiction, you are entitled to request us to erase any personal data we hold about you. See the Contact Us section below to submit a request for the deletion of personal information. Please note, we may require additional information in order to process your request.
Depending on your location and the applicable law, you may have additional rights as outlined in the Region Specific Terms.
We provide low-latency bandwidth and market data solutions for professional trading firms. We do not knowingly collect information from, or aim our services or products towards, children under the age of 18 or the age of majority as defined under applicable law.
We may process and store your personal data in the United States and other countries which may have less protective data protection laws than the region in which you are situated. Please note that this processing, including storage, may involve cross-border transfers of your personal data. In certain situations, we may be required to disclose personal data in response to lawful requests from officials (such as law enforcement or security authorities). Where applicable law requires a data transfer mechanism, we use one or more of the following:
For questions or concerns regarding this Policy, your privacy rights, or to exercise your rights as identified herein, you may contact us directly using the information below or submitting a request here.
| For US:
McKay Brothers, LLC and Quincy Data, LLC 2355 Broadway Attn: Privacy Compliance |
For outside the US:
McKay Brothers International SA 1, Avenue Saint Paul Attn: Privacy Compliance |
For the EEA:
Decyben SAS 23 Avenue Jean Moulin Attn: Privacy Compliance |
If you are a resident of the European Economic Area (“EEA”), Switzerland or the United Kingdom, you may have certain rights and protections under applicable law regarding the processing of your personal data. In the event of a conflict with the rest of our Policy, this Additional Information for Residents of the EEA, UK and Switzerland notice will prevail as to data subjects and their rights under the applicable privacy law.
Regulations require data processors to have a legal basis to process personally identifiable information. We rely on the following legal bases to process your information:
If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the data privacy authority where you reside. Where required, we have included contact details of your local Data Protection Authority.
| Jurisdiction | Data Protection Authority |
|---|---|
| EEA | https://edpb.europa.eu/about-edpb/board/members_en |
| Switzerland | https://www.edoeb.admin.ch/edoeb/en/home/the-fdpic/contact.html |
| UK | https://ico.org.uk/global/contact-us/ |
If you are a “consumer” (or analogous term) as defined under applicable state privacy laws in the United States, you may have certain rights and protections under applicable law regarding the processing of your personal data. In the event of a conflict with the rest of our Policy, this Additional Information for Residents of the United States, notice will prevail as to consumers and their rights under the applicable U.S. state privacy laws. We do not “sell” or “share” your personal data (as these terms are defined under U.S. state privacy laws). We also do not knowingly “sell” or “share” personal data about consumers under the age of 16. We do not use or disclose “sensitive personal information” for the purposes of inferring any characteristics about you or for any purposes that would require a user to exercise a right to limit according to California law.
Some privacy laws require a description of data practices using specific categories. The table below uses these categories to organize the information in this Policy. In the last 12 months, we collected and disclosed the following categories of personal data for the business or commercial purposes listed in this Policy. For more detailed information about the categories of sources, categories of personal data we collect, and the business or commercial purposes for collecting your personal data, please review the Information We Collect, How Do We Use Your Personal Data and Disclosure of Personal Data sections above.
| Categories of Personal Data | Examples of Personal Data Collected | Categories of Recipients with Whom Information May be Disclosed | Business Purposes for which Personal Data may be Collected or Disclosed |
| Identifiers |
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| Internet or other electronic network activity information |
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| Commercial Information |
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| Audio, electronic, visual or similar information |
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| Characteristics of Protected Classifications under California and Federal Law (For Employees and Job Applicants) |
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| Professional and employment-related information (For Employees and Job Applicants) |
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| Categories of Personal Information in Cal. Civ. Code Section 1798.80(e) (For Employees and Job Applicants) |
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| Non-public Education information (For Employees and Job Applicants) |
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| Other personal data |
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We store personal data for as long as necessary to carry out the purposes for which we originally collected it and for other business purposes explained in this Policy.
Under certain circumstances and in accordance with applicable privacy laws, you may have the following additional rights:
If we deny your request to exercise any of the rights you may have under applicable state law, you may appeal our decision by contacting us at the information listed above. If you have concerns about the results of an appeal, you may contact the attorney general or other regulatory authority in the state where you reside.
McKay also monitors and establishes other compliance measures for laws pertaining to privacy other than those set out in this Policy. Concerning such laws, McKay conducts annual training for applicable employees.
