Additional data privacy terms may apply to your use of certain services or products offered by OTC Markets Group.
PERSONAL DATA WE COLLECT
Your Browsing Activity
Like the operators of many other websites, we receive and collect information about your session, including the IP (internet protocol) address, domain name, browser type, operating system you use, the files you download, pages you visit and dates/times of those visits. This information about your session or about you may be collected by technology such as, "cookies" and "web beacons" (see “Cookies” section below). This information may be used by third party advertisers that we work with to provide advertisements to you (see “Third Party Advertising” section below).
Personal Data You Provide to Us
We collect and process personal information that you provide to us when you register to participate in a VIC (individually or on behalf of your employer/company, as an attendee, presenting company, or sponsor), or when you subscribe to newsletters or other communications, or by corresponding with us by phone, e-mail or otherwise using our contact details or providing your contact details or other information to us. This may include your name, phone number, email address, location, date of birth, title and other personal data provided at the time of requesting information or services from us, soliciting business, performing a service or negotiating a contract for products or services.
Personal Data Provided by Third Parties and Public Sources
In order to provide our services to our customers, we may rely on content and information provided by third party suppliers, customers, as well as content that is available to the public. Some of that information includes general business information about names and contact information of directors, board members, service providers and other official persons of companies published on publicly accessible websites and documents (for example, EDGAR company filings). Our customers may also transfer personal data to us in connection with their contractual obligations. For example, companies using the VIC may provide information to us about their officers and directors.
HOW WE USE PERSONAL DATA
We will typically only process personal information under the following circumstances:
- the processing is necessary to perform a contract with you (or your employer/ company) or take steps to enter into a contract at your request, such as to provide you with access to the VIC platform or other products or services that you have requested;
- the processing is necessary for us to comply with a relevant legal obligation, such as keeping accounting records;
- the processing is in our legitimate interests, which are not overridden by the interests and rights of the relevant individual whose personal data is collected; or
- you have consented to the processing.
Where our reason for processing personal information is because it is in our legitimate interests, our purpose for processing it will typically be one of the following:
- to identify you (or your employer/company) as a prospective customer for products or services and provide you with relevant information about these services and/or invitations to events;
- to manage our relationship with you by communicating with you (or your employer/company) about or providing to you our services;
- to carry out our contractual obligations to customers and users of our services and to exercise our rights and obligations under such contracts; to conduct, operate, market, and develop our business activities and improve our services in order to better serve our customers and users;
- to create aggregate data for informational materials and statistical reports related to our products and services;
- to improve the quality of our website(s) and tailor them to your preferences;
- to detect and prevent fraud to ensure the integrity of our markets, including by conducting surveillance of issuers and trading activities and reporting suspected misconduct to applicable regulators and authorities;
- to comply with our obligations as an operator of Alternative Trading Systems (e.g. Regulation Systems Compliance and Integrity);
- to monitor security threats involving the use of our products, website(s), or other services;
- to pursue and enforce our legal rights or defend claims or potential claims against us related to our business, products, and services; and/or to implement social networking features you have activated.
PERSONAL DATA WE DISCLOSE
We have disclosed certain categories of personal information to third parties over the past 12 months. The categories of the information disclosed and the third parties receiving the information are as follows:
- Attendee Data Provided to VIC Presenting Companies: When you register for to participate as an attendee in a VIC, we provide your information (including your name, contact information, email and other identifying information) to the presenting companies.
- Regulatory or Legal Requests: Personal information provided to federal and state agencies in response to requests, including contact information, employment information, civil or criminal history, information related to company ownership or other information described above related to your or your company’s use of our services.
- Third Party Service Providers: Personal information provided to third party vendors and business partners (e.g. video hosting and conferencing providers, described below), including website activity, contact information or other information described above related to your or your company’s use of our services.
- Our Subsidiaries: Personal information provided to our subsidiaries, OTC Link LLC, OTC Markets Group International Ltd., and Qaravan Inc., including website activity, contact information, employment information or other information described above related to your or your company’s use of our services.
THIRD PARTY Service Providers
We use the third-party service providers listed below in connection with the VIC, and these service providers may have access to the personal information that you provide to us. In using the VIC services, you are consenting to the use of your personal data as described in the applicable policies of our third party service providers, below:
- Notified (video hosting platform) Global Privacy Statement, Legal Terms Conditions & Policies
- Zoom (video conferencing services) Terms of Service, Privacy Statement
We log IP addresses and browser types for systems administration purposes and these logs will be analyzed to constantly improve the value of the materials available on our website(s). We also track and store users’ consent to our Terms of Service.
SECURITY OF YOUR INFORMATION
We keep personal data only for as long as required to fulfil the purposes for which it was collected (for example, to maintain an accurate record of customer dealings), subject to applicable legal, tax or accounting document retention requirements.
We take reasonable technical, administrative and physical security measures to protect your information, including applying generally accepted industry standards to protect the sensitive and/or personally identifiable information submitted to us during transmission and once we receive it. Despite these protections, however, we cannot guarantee that your data will be 100% secure. You should take measures to protect your personal information. If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please contact us immediately as detailed under the “Contact Us” heading below.
This website contains links to other sites. Please be aware that OTC Markets Group is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our website(s) and to read the privacy statements of each and every website that collects personally identifiable information. This privacy statement applies solely to information collected by OTC Markets Group.
We will take steps in accordance with applicable legislation to keep personal data accurate, complete and up-to-date. You are entitled to have any inadequate, incomplete or incorrect personal data corrected. You also have the right to request access to your personal data as well as to obtain additional personal data about the processing. In the event the lawful ground (see above) for processing your personal data is your consent, you have the right to withdraw consent at any time, without affecting the lawfulness of processing before withdrawal. Further, you are entitled to object to the processing of your personal data or to have your personal data erased, under certain circumstances.
Users located in the European Union have certain rights pursuant to the General Data Protection Regulation (“GDPR”). The following rights apply to processing of personal data which is subject to the GDPR: the right to access your personal information, erase your personal information, restrict our use of your personal information, object to our use of your personal information, receive your personal information in a usable electronic format and transmit it to a third party (right to data portability), and to lodge a complaint with the data protection authority in the European country where you work, reside, or where the subject-matter of your complaint or concern arises. If you wish to exercise any of your rights, or if you have any inquiries or complaints regarding the processing of your personal data, please contact us as detailed under the “Contact Us” heading below.
Users located in California have certain rights pursuant to the California Consumer Privacy Act (“CCPA”). The following rights apply to processing of personal data which is subject to the CCPA: the right to request disclosure of personal information collected, used or disclosed by OTC Markets Group (see Contact Us section), request deletion of personal information collected by OTC Markets Group, opt out of the sale of personal information and non-discriminatory treatment for the exercise of a user’s rights under the CCPA.
To help protect the privacy of individuals and companies who use our services, we will take reasonable steps to verify the identity of a request or before deleting or granting access to personal information in response to requests.
NOTIFICATION OF CHANGES
To contact us directly with any questions, comments or requests you may have regarding our business, services or your personal information, you can reach us by phone at +1 929.376.1493 or email us at firstname.lastname@example.org. We read every message sent in and try to reply promptly to every one. This information is used to respond directly to your questions or comments. We may also file your comments to improve our website(s) and program, or review and discard the information.
This policy is effective as of February 27, 2022.