Effective Date: September 12, 2019

This Privacy Policy applies to information that Tassat Group LLC may collect about you in connection with your access and use of the Tassat website located at www.tassat.com (the “Website”). In this Privacy Policy, “Tassat” refers to Tassat® Group LLC and its subsidiaries. Tassat offers certain services you may access through the Website (“Services”), including, but not limited to, trading and transaction services available to registered users on its electronic trading platform (the "Platform"), whether accessed through the Website, the Tassat API, or otherwise. Information collected in connection with Services may be governed by separate terms and conditions (“Tassat Terms”), such as Tassat Terms of Service, User License Agreements, applicable Rules, and/or a Participation Agreement between Tassat and the institution at which you are employed or on whose behalf you will be accessing the Platform or other Services, as agent (your “Institution”). To the extent that any of the Tassat Terms conflict with the terms and conditions in this Privacy Policy, the applicable Tassat Terms shall apply with respect to the relevant Service.

This Privacy Policy describes the type of information Tassat collects from the Website, and explains how Tassat gathers, uses, protects and shares it. Please read this Privacy Policy carefully and familiarize yourself with our privacy practices and procedures. Your continued use of the Website and Services constitutes your consent to the terms of this Privacy Policy and any updates. If you do not agree to this Privacy Policy, please do not use the Website.

1. Types of Information.

This section describes the various kinds of information that Tassat may collect and store as a result of your access and use of the Website.

a.) Registered User Information. While it is not necessary to register in order to visit the Website, some of the Services available through the Website may require you to be a registered user. In connection with any registration process, you or your Institution may need to provide certain Personal Information about yourself. “Personal Information” is any information that may be used to individually identify or personally contact you. Your Personal Information may include, but is not limited to, your name, employer, job title, email address, mailing address, phone number, confidential password, Internet Protocol (“IP”) address, geolocation data, and other identifying information you or your Institution may provide to Tassat.

Registered User Information may be collected and stored for purposes that include administering your access and use of any Services for which you are registered, securely identifying you when you log in to a Service, delivering Service-related notifications, providing customer support, and complying with applicable laws and regulations. Tassat may also use this information to occasionally contact you regarding Tassat products and services that may be of interest to you. If you decide, at any time, that you no longer want to receive any such marketing or promotional information, Tassat provides you with the ability to “opt out” by contacting us directly at [email protected].

b.) Website Usage Information. Tassat also collects Website Usage Information through your access and use of the Website. “Website Usage Information” includes both Personal Information and information that is anonymized, aggregated or otherwise presented in a way that does not allow individual identification of a user, or is not directly associated with a specific individual (“Non-Personal Information”). Website Usage Information is collected from both registered Tassat users and non-registered visitors to the Website. Such information is automatically captured whenever you visit the Website, and may include your IP address, your browser type, and any webpage that referred you to our Website. We may also store general usage and activity data, such as the date and duration of your visit, and your navigation of the Website. This type of data is used for the technical administration of the Website, to monitor and improve Website and Service performance, and to perform statistical analysis that helps us enhance the user experience and provide you with higher levels of customer service.

c.) Tracking Information. Tassat may collect additional information through the use of “cookies,” which are small data files placed on your computer’s hard drive to assign an identification code to your computer. Tassat may use cookies and other web technologies for reasons including, but not limited to, identifying a registered user who logs in to any Tassat Service through the Website, saving a registered user’s name and login password for future logins, enabling certain customized features, and storing your user preferences. We may also use cookies to collect aggregated user information that Tassat utilizes to improve the general operation of its Website and Services. You may set your computer’s browser preferences to remove and disable cookies. But please note that some features of the Platform may not be accessible or operate properly if you disable your cookies.

2. Sharing and Transferring Information.

This section describes how Tassat shares or transfers the Personal and Non-Personal Information it collects about you, as well as your ability to control how your information is shared with others.

a.) Personal Information. Except as provided in this Privacy Policy, Tassat will not disclose, transfer, sell, trade, rent, or otherwise provide your Personal Information to any third party, without your consent.

b.) Aggregated Data. Tassat may share Non-Personal Information, including log data and usage statistics, with third parties for purposes including but not limited to demographic, industry and marketing analysis, and the formation of business relationships.

c.) Service Providers. Tassat may use third party contractors to provide certain Website related services, such as maintenance services, hosting services or development services. Tassat may provide your Personal Information only to the extent necessary for such third party service providers to perform the duties for which it has been retained by Tassat. Any such third parties will be bound to strict confidentiality and use obligations with respect to your Personal Information, which are no less protective than those set out in this Privacy Policy.

Google Analytics. Google Analytics is as an analytics service provider. Learn more about how Google collects and uses data here. To opt out of Google Analytics Advertising Features please use Google Ad Settings. To opt out of Google Analytics entirely please use this link.

d.) Employers. If you are accessing any Service offered through the Website as a registered user of an Institution, Tassat is permitted to provide your Institution with any and all of your information, including but not limited to your Personal Information, access information and Website Usage Information.

e.) Legal and Contractual Compliance. Tassat may disclose your information to government or law enforcement officials, regulatory agencies or other third parties (such as attorneys or regulatory service providers), as necessary (in our sole discretion) to (i) comply with applicable laws or regulations, (ii) cooperate with governmental or law enforcement investigations, (iii) respond to legal claims or processes, (iv) protect the safety and legal rights of the public or any individual, (v) detect, prevent or remedy any suspected fraud, market manipulation or illegal, tortious or wrongful activity; or (vi) enforce applicable Tassat Terms to which you are bound.

f.) Business Transfers. If Tassat is acquired by, acquires or is merged with another company, Tassat may transfer Personal and Non-Personal Information about you to such company. In the event of such a business transfer, your information will remain subject to this Privacy Policy. Tassat will notify you if your information is subject to a business transfer and becomes subject to the other company’s privacy policy.

g.) Third Party Websites and External Links. Our Website may contain links to websites with which we have no affiliation or relationship. When you click on such links, you may leave our Website and be directed to the third parties’ websites. Except as provided in this Privacy Policy, we will not share any of your Personal Information with these websites; however, these websites may themselves collect Personal Information about you. Tassat is not, and will not be, responsible for the privacy practices or security of any such websites, and we urge you to read their privacy policies carefully.

Under California law, website operators are required to disclose how they respond to web browser “Do Not Track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Information of a consumer over time and across third party websites, to the extent the operator engages in that collection. At this time, Tassat does not track your Personal Information over time and across third-party websites.

3. Accessing and Managing Your Personal Information.

If you wish to review, update or correct any of your Personal Information, or “opt out” from any Website functionalities, you may contact us at [email protected]. If you are a registered user of any Services, you may make changes, additions or deletions to both Personal and Non-Personal Information, such as updating your user preferences, by logging onto your user account.

If you are submitting Personal Information as an administrator, on behalf of registered users at your Institution, you represent that you have full authorization to provide this information to Tassat.

4. Securing Your Information.

Tassat makes it a priority to protect your Personal Information. While no method of Internet transmission or electronic storage guarantees absolute protection, and Tassat provides no warranties, express or implied, that we can prevent unauthorized access to your Personal Information, we do employ a variety of reasonable security measures designed to guard against unauthorized access or use of your Personal Information. Such measures include physical and administrative security measures, strong authentication procedures and strict password protection, utilizing encryption software, transmitting your Personal Information over secure channels, and conducting penetration tests. In the event of any security breaches, we will make legally required disclosures to you via email or by providing notice on the Website.

5. Children.

The Website and Tassat’s Services are not intended for children under eighteen (18) years of age. Tassat does not market any products or services to children under eighteen (18) years of age or knowingly collect any information from children under eighteen (18) years of age.

6. Notice of Privacy Rights to California Residents.

California law requires certain businesses to respond to requests from California users who ask about business practices related to disclosing Personal Information to third parties for direct marketing purposes. The California "Shine the Light" law further requires us to allow California residents to opt out of certain disclosures of Personal Information to third parties for their direct marketing purposes. Please contact us via email at [email protected] in order to submit a request. We will respond to the request in accordance with applicable law.

7. Notice to Individuals in the European Economic Area and Switzerland

This section only applies to individuals using or accessing our Services while located in the European Economic Area, the United Kingdom, or Switzerland (collectively, the “European Countries”) at the time of data collection.

We may ask you to identify which country you are located in when you use or access some of the Services, or we may rely on your IP address to identify which country you are located in. When we rely on your IP address, we cannot apply the terms of this section to any individual that masks or otherwise hides their location information from us so as not to appear located in European Countries. If any terms in this section conflict with other terms contained in this Policy, the terms in this section shall apply to individuals in a European Country.

Our Relationship to You. Tassat is a data controller with regard to any Personal Information collected from individuals accessing or using its Services. A “data controller” is an entity that determines the purposes for which and the manner in which any Personal Information is processed.

Legal Bases for Processing Your Personal Information. We rely on the following Legal Bases in processing your Personal Information.

a) Our processing is based on our contract obligations or to take steps at the request of the individual prior to entering into a contract.

b) Our processing is based on our legitimate interest to better understand you, to maintain and improve the accuracy of the information we store about you, and to better promote or optimize our Services.

c) Our processing is based on our need to comply with our legal obligations, the public interest, or in your vital interests.

Marketing. If you are located in a European Country, we will only contact you by electronic means (including email or SMS) based on our legitimate interests, as permitted by applicable law or your consent. If you do not want us to use your Personal Information in this way, please click the unsubscribe link at the bottom of any of our email messages to you or contact us at [email protected]. You can object to direct marketing at any time, free of charge.

Individual Rights. We provide you with the rights described below when you use our Services. We may limit your individual rights requests: (a) where denial of access is required or authorized by law; (b) when granting access would have a negative impact on other’s privacy; (c) to protect our rights and properties; or (d) where the request is frivolous or unrealistic. If you would like to exercise your rights under applicable law, please contact us at [email protected].

  • You can request access or deletion of your Personal Information.
  • You can correct or update your Personal Information, object to processing or your Personal Information, ask us to restrict processing of your Personal Information or request portability of your Personal Information.
  • If we collected and processed your Personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of the processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
  • You have the right to complain to your local data protection authority about our collection and use of your Personal Information.

If you believe we have infringed or violated your privacy rights, please contact us at [email protected] so that we may resolve your dispute directly.

8. Changes to Our Privacy Policy.

This Privacy Policy may be revised from time to time. Please visit this section of the Website periodically to check for changes and updates to the Privacy Policy. We will post a copy of any revised Privacy Policy on the Website fifteen (15) days prior to its becoming effective. By continuing to access and use the Website and/or any Service after such fifteen-day notice period, you agree to be bound by the terms of the revised Privacy Policy.

9. Compensation History.

Applicants for employment are not asked to, and should not under any circumstances, disclose their current or prior salaries, wages, benefits, allowances, retirement plans, bonuses, commissions, profit percentages, or other compensation at any time during the application or hiring process.

10. Contact Us.

If you have questions or comments about our privacy practices, please contact us via email at [email protected].