Revision date 12/19/2011
You can count on us to protect the privacy of the information you have entrusted to us and to provide you with the responsive, professional service you deserve.
We recognize that the trust of our clients is our most precious asset. SecondMarket is committed to maintaining the confidentiality, integrity and security of personal information regarding our clients. Keeping client information secure, and using it only as our clients want us to, are matters of principle for all of us at SecondMarket. With this in mind, here is our pledge to each and every SecondMarket Inc. client and user of any SecondMarket Holdings website:
SecondMarket does not sell personal information about its clients or users to anyone.
We collect information from you that is required to open an account, to transact business, to communicate with you, verify your identity and fulfill legal and regulatory requirements. We call this your “Profile.” From time to time, we may request additional information (e.g., through surveys) to help us further assess your needs and preferences.
We also offer the option to allow you to share certain information with other clients and users of the SecondMarket Platform. You can share your profile with everyone on the SecondMarket Platform, or only with members whom you designate as “Trusted Connections.” You are not required to select anyone as a “Trusted Connection”, and thus you do not have to share your Profile with anyone other than SecondMarket employees and contractors who have a need to know your Profile information in order to service your account. Anyone you do designate as a “Trusted Connection”, will be able to see your bidding, offering and trading activity in addition to your Profile. In the event you indicate an interest to buy a particular asset, we will notify the issuer of that asset of your interest, unless you deselect the box next to the words "Share your name and interest to buy with [Name of Issuer]".
The information we collect and maintain about you comes primarily from you during the course of your doing business with SecondMarket Inc. This personal information, not available publicly, comes from the following sources:
Information you provide to us when you fill out account opening documents, complete a form or make a request for services, including your name, address, age, Social Security number and/or taxpayer identification number, investment objectives, investment experience, assets and income, telephone number, e-mail address and similar information;
Information from your transactions with us, such as your account balance and account usage; and
Information obtained from others, such as credit reporting agencies.
SecondMarket considers the protection of sensitive information to be a foundation of client trust.
Keeping Information Safe
We limit access to the information we have about you to those employees who need to know to provide you with services to help you meet your financial needs. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards and controls to protect your information.
We have invested in software, systems and procedures to offer you a safe and secure trading environment and protect your personal, financial and trading information. While no security system is absolutely impenetrable, we plan to constantly review, refine and upgrade our security technology as new tools become available.
The Importance of Being Accurate
We have security standards and procedures in place designed to prevent unauthorized access to your accounts and personal information. A key part of this process helps ensure that all information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your personal information changes, we urge you to notify us immediately.
We only use your information as appropriate to provide you with quality services and to ensure security. For example, we may use the information collected from you to verify your identity and contact information. We may also use this information to establish and set up your trading account, issue an account number, and maintain your trading information. This information helps us improve our services to you.
An Ongoing Commitment to Your Privacy
We are just as committed to protecting the privacy of our former clients as we are our current clients. If you choose to become an inactive client, you will continue to be protected by the privacy policies and principles described in this policy. Should you close your account with us, SecondMarket Inc. will retain your information, but only use it to comply with regulatory requirements.
How Information Helps Both You and Us
Our mission is clear: to help you reach your financial goals. Information about you and your accounts plays a key role in our ability to succeed in this mission. It also helps us service your accounts and administer our business. For example, we use information about you to:
We Limit the Sharing Information
To protect your privacy, we limit the sharing of information outside SecondMarket. We conduct our business with great respect for the confidential nature of the information being provided. We will not share information about you except as outlined below.
Examples of the types of outside companies with which we may share information include non-financial companies that perform services for us, such as data processing and companies that perform securities execution and clearing services on our behalf. SecondMarket Inc. has entered into contractual arrangements with Penson Financial Services, Inc. ("Penson") to provide clearing and settlement services, and Continental Stock Transfer and Trust Company for escrow services to SecondMarket Inc. and its clients. SecondMarket Inc. may provide client information to either of these entities when it is necessary to do so to service and settle trades on a timely basis.
SecondMarket Inc. may share information with affiliates if the information is required to provide the services you requested. An affiliate is a company that we own or control, or with which there is common ownership with us.
As noted above, SecondMarket Inc. also reserves the right to disclose your personal information where required by law to regulatory, law enforcement or other government authorities. We may also disclose your information as necessary to credit reporting or collection agencies, or when necessary to protect our rights or property.
The following additional information will be of interest to you if you access SecondMarket and/or one of its affiliates products or services through one or more of our websites:
Users of SecondMarket, Inc. websites are required to identify and authenticate themselves prior to accessing our services. Generally, identification and authentication take place through the use of your user name and a password and/or while logging in with one of our Technical Support Staff.
Security is a cooperative effort between us and the users of our websites. Please remember that your user identification and password are personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them.
Web surfing data (e.g., information regarding which of our web pages you access, the frequency of such access, and your product and service preferences) may be collected by SecondMarket itself, or by our service providers. This may be accomplished by using cookies, Web beacons, page tags or similar tools that are set when you visit our website. Web surfing data and similar information may be shared internally within SecondMarket and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our websites; and as otherwise permitted by applicable law or regulation. If you are a SecondMarket, Inc. client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by third parties, solely in accordance with our instructions.
SecondMarket, Inc. has also entered into a contractual arrangement with Omniture, Inc. ("Omniture") to provide internet consulting services and reports. SecondMarket, Inc. may transmit any information provided by you to Omniture that is necessary for Omniture to provide business optimization services including website tracking, recording, reporting, behavioral targeting, testing and optimization, keyword bid management, search engine functionality, and website content publishing.