Privacy Policy

Polygon.io, Inc. ("Polygon", "we", "our", or "us") is committed to protecting your ( "you" or "your") privacy and empowering you with this privacy policy (this "Privacy Policy"). This Privacy Policy explains how we collect, use, disclose, and apply the information collected when you use or access our website (https://polygon.io/), products, services, or applications that post a link to this Privacy Policy (collectively, the "Services").

By using or accessing any part of the Services or interacting with us, you are agreeing to this Privacy Policy. Please read the following carefully to understand how we collect, use, disclose, and maintain information that can be used to identify you ("Personal Data"). In addition, this Privacy Policy describes your choices for use, access, and correction of your Personal Data. If you do not agree to be bound by this Privacy Policy, please deactivate your account and stop using the Services.

We may change this Privacy Policy from time to time. In the event we make changes, we will notify you by revising the "Last Updated" date at the top of this Privacy Policy. Any changes are effective when we post the revised Privacy Policy on the Services. We encourage you to review our Privacy Policy whenever you use the Services to stay informed of ways you can protect your privacy.

We may provide you with disclosures and alerts regarding this Privacy Policy or Personal Data collected by posting them on our website and, if you are a Subscriber, by contacting you through your Polygon dashboard and/or email address listed in your Polygon account.

If applicable law requires that we provide notice in a specified manner before making any changes to this Privacy Policy applicable to you, we will provide such required notice.

Personal Data is collected from you directly, automatically from your device, and also from third parties. The Personal Data we process when you use the Services depends on variables like how you interact with our Services, the features you use, and your method of accessing the Services. Below, we detail the information we collect through each of these channels.

• Account Data: We collect certain information when you open an account such as your email address, password, and photo. Depending on your subscription, we may also collect your physical address, your employer name, your employer's address, your job title and functions, and your signature.
• Feedback Data: This consists of information you submit through surveys, reviews, or interactive features.
• Payment Information: For paid subscriptions, we collect details like email, billing address, and payment specifics. Payment information is collected by Stripe, Inc., our payment processor.
• Sales and Marketing Data: This includes information provided for promotional communications, such as email addresses.
• Support Data: When you seek customer support, we collect the information that you provide.

• Buttons, Tools, and Content from Other Companies: Our Services may contain links or buttons that lead to third-party services like Twitter or LinkedIn. The use of these features may result in data collection. Engaging with these buttons, tools, or content may automatically send certain browser information to these companies. Please review the privacy statements of these companies for more information.
• Cookies and Other Tracking Technologies: We use cookies and similar technologies to provide essential functionality like storing settings and recognizing you while using our Services. See the "Cookies and Other Technologies" section below for more details and control options.
• Email Marketing Interactions: Our emails may have web beacons that offer information on your device type, email client, email reception, opens, and link clicks.
• Geolocation Information: Depending on the Service's functionality, we collect regional geolocation data based on your IP address.
• Service Usage Information: We collect data about your interactions with the Services, such as IP address, device information, session details, dates and times related to financial market data access, date and time of API requests, device type and ID, operating system and application version, and performance of specific features or Services.
• Website Usage Data: We automatically log data about your website interactions, including the referring site, date and time of visit, pages viewed, and links clicked.

• Information from Other Users of the Services: If you are part of an organization, we may receive information about you if you are identified as a representative or administrator of your organization's account.
• Publicly Available Sources: We may acquire information about you from publicly available sources.
• Services you linked to your account: If you sign up for the Services using Facebook, Github, or Google, we receive information based on your settings with those services. This can include details like your name and email from these services. The information we receive depends on the third party's settings and privacy policies. Always review these to understand what data is shared with our Services.
• Vendors and Partners: We may receive information about you from third parties, like vendors, resellers, or partners for the purposes outlined in this Privacy Policy.

A cookie is a small text file that can be stored on and accessed from your device when you visit our Services, to the extent you agree. The other tracking technologies work similarly to cookies and place small data files on your devices or monitor your website activity to enable us to collect information about how you use our Services. This allows our Services to recognize your device from those of other users of the Services. The information provided below about cookies also applies to these other tracking technologies. You can find more useful information about cookies and other similar tracking technologies at www.allaboutcookies.org and www.youronlinechoices.eu.

Like most providers of online services, we use cookies and other tracking Technologies, including first-party cookies (i.e., cookies placed by us when you use the Services) and third-party cookies (as explained below), for a number of reasons, like identifying you, helping us see which features are most popular, counting visitors to a page, understanding how you engage with web content and emails we send, improving our users' experience, keeping the Services secure, tracking and analyzing statistical usage and volume information from our users, providing relevant advertising, and just generally providing you with a better, more intuitive, and satisfying experience.

Some cookies and other tracking technologies that we use are from third-party companies (third-party cookies), such as Google and Hotjar to provide us with web analytics and intelligence about our website which may also be used to provide measurement services and target ads. These companies use programming code to collect information about your interaction with our website, such as the pages you visit, the links you click on, and how long you are on our website. This code is only active while you are on the Polygon website. For more information on how these companies collect and use information on our behalf, please refer to their privacy policies.

Depending on the Services, we may use the following types of cookies:

Necessary

Necessary cookies help make the Services usable by enabling basic functions like page navigation and access to secure areas of the Services. The Services cannot function properly without these cookies. Disabling these cookies may make the Services unavailable.

Preferences

Preference cookies are used by us to remember your settings and preferences and to improve your experience on our Services

Analytics

Analytics cookies help us collect information about your use of the Services and enable us to improve the way it works. These cookies give us aggregated information that we use to monitor the Services’ performance, count page visits, spot technical errors, see how users reach the Services, and measure the effectiveness of marketing (including emails).

Marketing

Marketing cookies are used to show consumers display advertisements across websites, to make them more relevant and meaningful to consumers, and to track the efficiency of our advertising campaigns, both on our services and on other websites or mobile apps. Our third-party advertising partners (as identified above) may use these cookies to build a profile of your interests and deliver relevant advertising on other sites.

If you do not want cookies to be dropped on your device, you can adjust the settings of your Internet browser to reject the setting of all or some cookies and to alert you when a cookie is placed on your device. For further information about how to do so, please see the specific browser procedures below, or see www.allaboutcookies.org. Please note that if you use your browser settings to block all cookies (including strictly Necessary Cookies), you may not be able to access or use all or parts of our Services or specific functionalities.

• Chrome
• Safari
• Safari Mobile (iPhones and iPads)
• Firefox
• Microsoft Edge

If you want to remove previously stored cookies, you can manually delete the cookies at any time. However, this will not prevent the Services from placing further cookies on your device, unless and until you adjust your Internet browser setting as described above.

You may opt-out of behaviorally targeted ads anytime by clearing your cache of your browser's cookies. Additionally, you may opt out of interest-based advertising from some third-party partners by visiting http://preferences-mgr.truste.com/, http://www.youronlinechoices.eu, or the third-party provider's websites. Please note that opting-out will only prevent targeted ads so you may continue to see generic (non-targeted ads) after you opt-out.

We use the Personal Data we collect from you for the following purposes:

• To provide and maintain our Services;
• For the performance of a contract such as the development, compliance, and undertaking of the purchase contract for the Services you have purchased or of any other contract with us through the Services;
• To support our legitimate interests in maintaining and improving our Services;
• To contact you with special offers, promotions, and other information we believe will be of interest to you;
• To provide the information, products, and services you request;
• For internal administrative and auditing purposes;
• To detect security incidents and protect against malicious, deceptive, fraudulent, or illegal activity, including, when necessary, to prosecute those responsible for such activities;
• For other purposes such as data analysis, identifying usage trends, determining the effectiveness of our promotional campaigns, and evaluating and improving our Services, products, marketing, and your experience;
• To invite you to participate in surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us);
• To enforce our policies or other agreements;
• To combine information collected through the Services and from other sources so that such information can no longer reasonably be linked to you or your device ("De-Identified Information") such as de-identified demographic information, information about the device from which you access the Services, or other analyses we create;
• To use for any other purpose for which we provide notice at the time of collection; and
• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

We do not sell Personal Data to third parties or otherwise share it with non-agent third parties. If this practice should change in the future, we will update this Privacy Policy to identify the parties and illustrate how individuals can exercise their right to opt-out of such usage.

We may share your Personal Data with third-party vendors that perform tasks on our behalf such as billing and collection, IT services, maintenance and hosting of our Services, payment processors, marketing partners, accounting, auditing, tax, legal, and other professional services. These third-party vendors may use your Personal Data only in connection with the services they perform on our behalf, and they are bound to protect your Personal Data in a manner substantially consistent with our own policies and practices. Depending on your subscription, we may share your Personal Data with national securities exchanges, securities information processors, or our other third-party financial data providers for the purposes described in this Privacy Policy. In addition, you may choose to use certain features on our website for which we partner with other entities. These features are operated by third parties that are not affiliated with us. These third parties may use your Personal Data in accordance with their privacy policies. In the parts of the Services on which these features are offered, the relevant third parties are identified. We strongly suggest you review the third party's privacy policies if you use the relevant features.

We may share or disclose your Personal Data for other purposes pursuant to your consent or with your further direction.

From time to time, we may share De-Identified Information about use of the Services, such as by publishing a report on usage trends. The sharing and our other use of such data is unrestricted.

We may also disclose your Personal Data when we, in good faith, believe disclosure is appropriate to comply with the law, a court order, or a subpoena. We may also disclose your Personal Data to prevent or investigate a possible crime, such as fraud or identity theft, to protect the security of our Services, to enforce or apply our policies or other agreements, or to protect our own rights or property or the rights, property or safety of our users or others. We will attempt to notify our users about legal demands for their Personal Data when appropriate in our judgment, unless prohibited by law or court order or when the request is an emergency. We may dispute such demands when we believe, in our discretion, that the requests are overbroad, vague, or lack proper authority.

As we continue to develop our business, we may buy, merge, or partner with other companies. In such transactions (including in contemplation of such transactions), Personal Data may be among the transferred assets. If a portion or all of our assets are sold or transferred to a third party, your Personal Data would likely be one of the transferred business assets. If such transfer is subject to additional mandatory restrictions under applicable laws, we will comply with such restrictions.

If you have registered for an account, you may access, review, update, or delete certain Personal Data that you have provided to us by logging into your account and using available features and functionalities or by contacting us in accordance with the "Contact Us" section below. You may also contact us to delete your account. Please note that we will need to verify that you have the authority to delete the account and certain activity generated prior to deletion may remain stored by us and may be shared with third parties as detailed in this Privacy Policy.

You have a choice, at any time, to stop us from sending you emails for marketing purposes by following the "unsubscribe" link included in these messages. Please note that despite any indicated e-mail marketing preferences, we may continue to send you administrative emails, including, for example, notices of updates to our policies including this Privacy Policy, if we choose to provide such notices to you in this manner.

In certain circumstances providing Personal Data is optional. However, if you choose not to provide Personal Data that is needed to use some features of our Services, you may be unable to use those features. We will tell you what Personal Data you must provide to receive the Services.

Some browsers offer a "do not track" ("DNT") option. Since no common industry or legal standard for DNT has, to date, been adopted by industry groups, technology companies, or regulators, we do not respond to DNT signals. We will make commercially reasonable efforts to continue to monitor developments around DNT browser technology and the implementation of a standard.

Individuals in the European Economic Area, Switzerland, the United Kingdom, Brazil, and across the globe have certain statutory rights in relation to their Personal Data. Subject to any exemptions as provided by law, you may have certain rights regarding the Personal Data we, acting as the data controller, maintain about you. If, at any time, you wish to exercise your rights, please reach out to us in accordance with the "Privacy Rights Request" section below.

• Right of Access. If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge you a reasonable fee.
• Right to Rectification. If your Personal Data is inaccurate or incomplete, you are entitled to ask that we correct or complete it.
• Right to Erasure. You may ask us to erase your Personal Data in some circumstances, such as where we no longer need it or you withdraw your consent (where applicable) and there is no other legal basis for processing.
• Right to Restrict Processing. You may ask us to restrict or 'block' the processing of your Personal Data in certain circumstances, such as if you contest its accuracy or object to us processing it.
• Right to Data Portability. You have the right to obtain your Personal Data from us that you consented to give us or that was provided to us as necessary in connection with our contract with you, and if the processing is carried out by automated means.
• Right to Object. You may ask us, at any time, to stop processing your Personal Data, and we will do so: (a) if we are relying on a legitimate interest to process your Personal Data, unless we demonstrate compelling legitimate grounds for the processing or your data is needed to establish, exercise, or defend legal claims; or (b) we are processing your Personal Data for direct marketing and, in such case, we may keep minimum information about you (for example, in a suppression list) as necessary for our and your legitimate interest to ensure your opt-out choices are respected in the future and to comply with data protection laws.
• Right to Withdraw Consent. If we rely on your consent to process your Personal Data, you have the right to withdraw that consent at any time, but this will not affect any processing of your data that has already taken place.
• Right to lodge a Complaint. If you have a concern about our privacy practices, including the way we handled your Personal Data, you can report it to the data protection authority that is authorized to hear those concerns.

If you are a resident of the State of California, Colorado, Connecticut, Utah, or Virginia in the United States, please see below for additional state-specific privacy disclosures. Unless otherwise expressly stated, all terms defined in our Privacy Policy retain the same meaning in these Disclosures.

In addition, we may at times receive or process Personal Data to create de-identified data that can no longer reasonably be used to infer information about, or otherwise be linked to, a particular individual or household. Where we maintain deidentified data, we will maintain and use the data in deidentified form and not attempt to reidentify the data except as required or permitted by law.

Depending on your state of residency and subject to certain legal limitations and exceptions, you may be able to exercise some or all of the following rights:

• Right to Know. If you ask us, we will confirm whether we are processing your Personal Data and, if so, provide you with a copy of that Personal Data along with certain other details. If you require additional copies, we may need to charge you a reasonable fee.
  • The categories of Personal Data collected;
  • The categories of sources of the Personal Data;
  • The purposes for which the Personal Data were collected;
  • The categories of Personal Data disclosed to third parties (if any), and the categories of recipients to whom the Personal Data were disclosed;
  • The categories of Personal Data shared for cross-context behavioral advertising purposes (if any), and the categories of recipients to whom the Personal Data were disclosed for those purposes; and
  • The categories of Personal Data sold (if any), and the categories of third parties to whom the Personal Data were sold.
• Right to Access and Portability. The right to obtain access to the Personal Data we have collected about you and, where required by law, the right to obtain a copy of the Personal Data in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another entity without hindrance.
• Right to Correction. The right to correct inaccuracies in your Personal Data, taking into account the nature of the Personal Data and the purposes of the processing of the Personal Data.
• Right to Deletion. The right to have us delete the Personal Data we maintain about you.
• Right to Opt-Out of Sales or Sharing of Personal Data. The right to direct us not to “sell” your Personal Data to third parties for monetary or other valuable consideration, or “share” your Personal Data to third parties for cross-context behavioral advertising purposes and targeted advertising purposes.

Depending on your state of residency, you may also have the right to not receive retaliatory or discriminatory treatment in connection with a request to exercise the above rights. However, the exercise of the rights described above may result in a different price, rate or quality level of product or service where that difference is reasonably related to the impact the right has on our relationship or is otherwise permitted by law.

In addition to the above, residents of the State of California in the United States who have an established business relationship with us have the right to know how their Personal Data is disclosed to third parties for their direct marketing purposes during the preceding year under California's "Shine the Light" law, or the right to opt-out of such practices. California residents may contact us in accordance with the 'Privacy Rights Requests' section below. You will need to attest to the fact that you are a California resident.

If you are a resident of the State of Nevada in the United States, Chapter 603A of the Nevada Revised Statutes permits a Nevada resident to opt-out of potential future sales of certain covered information that a website operator has collected or will collect about the resident. We do not engage in such activity; however, if you are a Nevada resident who has purchased services from us, you may submit a request to opt-out of any potential future sales under Nevada law by contacting us in accordance with the “Privacy Rights Requests” section below. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

To submit a request to exercise one of the privacy rights identified above, please contact us at compliance@polygon.io.

We may need to verify your identity before processing your request. In order to submit a request, you'll need to log in to your account with us so we can verify your identity. If you can't log in or don't have an account, we may not be able to link you to any Personal Data of yours on our systems, but we'll do our best. In certain circumstances, we may decline a request to exercise the rights described above, particularly where we are unable to verify your identity or locate your information in our systems. We will only use Personal Data provided in connection with a rights request to review and comply with the request.

You do not need to create an account with us to exercise your Right to Opt Out. However, we may ask you to provide additional Personal Data so that we can properly identify you to track compliance with your opt-out request. We will only use Personal Data provided in an opt-out request to review and comply with the request. If you choose not to provide this data, we may only be able to process your request to the extent we are able to identify you in our data systems.

In certain circumstances, you are permitted to use an authorized agent to submit requests on your behalf through the designated methods set forth above where we can verify the authorized agent's authority to act on your behalf. In order to verify the authorized agent's authority, we generally require evidence of either: (a) a valid power of attorney; or (b) a signed letter containing your name and contact information, the name and contact information of the authorized agent, and a statement of authorization for the request. Depending on the evidence provided and your state of residency, we may still need to separately reach out to you to confirm the authorized agent has permission to act on your behalf and to verify your identity in connection with the request.

Depending on your state of residency, you may be able to appeal a decision we have made in connection with your privacy rights request. All appeal requests should be submitted via email to compliance@polygon.io.

Polygon takes all reasonably necessary precautions, such as implementing a combination of physical, technical, organizational, and administrative safeguards, to protect the information we collect through the Services. Although we take reasonable steps designed to protect your Personal Information, please be advised that no security system or means of transmitting data over the Internet can be guaranteed to be entirely secure (including without limitation with respect to computer viruses, malicious software, and hacker attacks). We cannot promise that we, or operators who work on our behalf, can withstand security threats in all circumstances.

We retain Personal Data as long as we are providing the Services to you or for a period during which we reasonably anticipate providing the Services. Even after we stop providing services directly to you, and even if you close your account, we may retain your Personal Data to fulfill our contractual obligations, comply with our legal requirements, resolve disputes, and enforce agreements. 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.

To provide you with the Services, we may store, process, and transmit data in the United States and locations around the world—including those outside of your country. Your Personal Data, therefore, may be subject to privacy laws that are different from those in your country. Personal Data collected within Europe may, for example, be transferred to and processed by third parties located in a country outside of Europe. In such instances, we shall ensure that the transfer of your Personal Data is carried out in accordance with applicable privacy laws and, in particular, that appropriate contractual, technical, and organizational measures are in place.

Our Services may include links to or redirect you to third-party websites, plug-ins, and applications, including social media services where you may connect with us. Third-party websites may also reference or link to our websites and online services. Except where we post, link to, or expressly adopt or refer to this Privacy Policy, this Privacy Policy does not apply to, and we are not responsible for, any Personal Data practices of third-party websites and online services or the practices of other third parties. To learn about the Personal Data practices of these third parties, please visit their respective privacy notices or policies.

The Services are directed to individuals at the age of 18 and over. We do not knowingly collect Personal Data from individuals under the age of 18. If we become aware of individuals who have provided us with Personal Data and are under the age of 18, we will take steps to deactivate the account and delete the Personal Data. If you become aware of information from Children which has been provided to us, please contact us in accordance with the "Contact Us" section below.

If you have any questions or concerns about our Privacy Policy, please contact us via email at compliance@polygon.io.