Legal

Privacy Policy

Last Updated: February 2, 2023

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/) (the "Site"), products, services, or applications that posts a link to this Privacy Policy (collectively, the "Services").

By using or accessing the Site or 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.

1. Changes to this Privacy Policy.

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 Site 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 prior to making any changes to this Privacy Policy applicable to you, we will provide such required notice.

2. How We Collect Personal Data.

We may collect Personal Data about you by the following means:

  • Directly from you, when you provide information to us or interact with us or our affiliates;

  • Automatically when you, or Subscriber(s), utilize or interact with our Site or our Services;

  • From online advertising companies who may share information about the marketing and advertisements you have seen or clicked on, and from social networks and other sources of publicly available data;

  • From other third party sources that provide consumer data, such as information about your interests, demographic information, and marketing inferences.

3. What Personal Data We Collect.

The Personal Data that we collect varies depending on whether you are a:

  • "Visitor" meaning anyone accessing the Site;

  • "Subscriber" meaning any customer that has entered into an agreement with Polygon to use the Services, including those using free trials or free plans, and any of a customer's authorized users; or

  • "Edge User" meaning a visitor to or customer of a website or mobile application of a Subscriber.

Please note that some of the Personal Data collected is through cookies, web beacons, and other tracking technologies, which may be operated by our partners who assist us in serving ads or providing other services to you.

3.1 Visitor.

This section applies to Personal Data we may process in the usual course of business via the Site.

  • Usage Details about your interaction with our Site (such as the pages visited, links clicked, non-sensitive text entered, referring URL, length if your visit or time spent on a page, and other details of your actions on our Site);

  • Log Data including IP address, timestamps, browser information, Internet Service Provider “ISP”, web pages visited, and URL of the web page you visited before navigating to our Site;

  • Device Information including the IP address and other details of a device that you use to connect with our Services (such as browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, e.g., a persistent device identifier or an Ad ID), and other such information);

  • Location Information from publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address;

  • Survey Information in response to questions we may send you through the Services, including for feedback and research purposes;

  • Biographical Information when you inquire about or apply for a position with us; and

  • User Content you may provide to publicly post to our social media sites via the Services (e.g., comments).

3.2 Subscriber.

This section applies to Personal Data of Subscribers that we may process via provision of the Services.

  • Profile and Subscription Information , such as a username and password, your name, physical address, e-mail address, social media profile information if you sign into the Services using Github or Facebook, subscription preferences, employer address, investment background information, occupation/title, and electronic signature when you create an account to license the Services;

  • Transactional Information including payment information (collected by Stripe, Inc., our payment processor) and payment history if you engage in transactions through the Services;

  • Log Data including IP address, timestamps, browser information, Internet Service Provider “ISP”, web pages visited, and URL of the web page you visited before navigating to our Site;

  • Usage Details about your interaction with our Services (such as API usage and the Site pages visited, links clicked, non-sensitive text entered, referring URL, length of your use of the Services, time spent on a page on the Site, and other details of your actions on the Services);

  • Device Information including the IP address and other details of a device that you use to connect with our Services (such as browser type, Internet service provider, platform type, device type/model/manufacturer, operating system, date and time stamp, a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, e.g., a persistent device identifier or an Ad ID), and other such information);

  • Location Information we use publicly available sources to approximate your geographic region and Internet Service Provider based on your IP address;

  • Contact Information and any other information you choose to include when you communicate with us via email, Slack, mail, or other channels;

  • Survey Information in response to questions we may send you through the Services, including for feedback and research purposes; and

  • User Content you may provide to publicly post to our social media sites via the Services (e.g., comments).

3.3 Edge User.

For Edge Users, Polygon is acting as a service provider (or processor) to the Subscriber for the Services. Polygon collects Personal Data at the direction of the Subscriber, and has no direct relationship with the Edge User whose Personal Data it processes. It is important to understand that when an Edge User visits other websites that use the Services, the Subscriber's privacy policy applies to that information collected instead of this Privacy Policy.

This section applies to Personal Data Polygon may process relating to Edge Users of a Subscriber's website and mobile apps.

  • Usage and Session Information Specifically, we collect information about an Edge User's including:

    • Log information (i.e., IP address, browser type and settings, the date and time the Services were used, information about browser configuration and plugins, and language preferences),

    • Information about devices accessing the Services, including type of device, what operating system is used, device settings, application IDs, unique device identifiers and crash data, and

    • Interactions with our Services when using a Subscriber's website or app.

4. Cookies and Other Technologies.

4.1 Cookies and Other Technologies.

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.

4.2 How We Use Cookies and Other Tracking Technologies.

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.

4.3 Third-Party Cookies.

Some Cookies and Other Tracking Technologies that we use are from third party companies (third party cookies), such as Google, Microsoft, Reddit, Elite Trader, 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.

4.4 Cookies We Use.

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

Cookie Category
Why do we use these 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.

4.5 Managing Cookies

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 or specific functionalities, of our Services.

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.

5. How We Use Your Information.

We use the Personal Data we collect from Visitors and Subscriber 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 of 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 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 use the Personal Data we collect from Edge Users for the following purposes:

  • For the performance of the contract with the Subscriber;

  • To perform any other function that we believe in good faith is necessary to protect the security or proper functioning of the Site or the Services;

  • To comply with legal requirements and industry standards, detect, investigate, and prevent activities that may violate our policies or be fraudulent or illegal, and protect the rights of Polygon, you, or others;

  • To manage, operate, and improve the Services; and

  • To monitor the performance of our Services including metrics such as total number of visitors and traffic.

We do not sell Visitor, Subscriber, or Edge User 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.

7. How We Share and Disclose Information.

7.1 Service Providers and Third-Parties.

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. On the parts of the Services on which these features are offered, the relevant third-parties are identified. We strongly suggest you review the third-parties' privacy policies if you use the relevant features.

7.2 Your Consent.

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

7.3 De-Identified Data.

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.

7.4 Legal Reasons.

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.

7.5 Sale, Merger, or Other Business Transfer.

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.

8. Your Choices.

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 that you must provide in order 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.

9. Jurisdiction-Specific Provisions.

9.1 International Privacy Disclosures. 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.

9.2 U.S. State Privacy Disclosures.

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.

The following Personal Data elements we collect may be classified as "sensitive" under certain privacy laws ("sensitive information"):

  • Username and password; and

  • Precise geolocation data.

We use this sensitive information for the purposes set forth in the “What Personal Data We Collect section and the “Cookies and Other Technologies” section above, to enter into and perform a contract with you, to comply with legal and regulatory requirements, or as otherwise permissible for our internal business purposes consistent with applicable laws. We do not sell your sensitive information, and we do not process or otherwise share sensitive information for the purpose of targeted advertising.

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 that have an established business relationship with us have rights 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.

10. Privacy Rights Requests.

10.1 Submitting Privacy Rights Requests.

To submit a request to exercise one of the privacy rights identified above, please contact us at support@polygon.io or by filling out this form.

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.

10.2 Submitting Authorized Agent Requests.

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.

10.3 Appealing Privacy Rights Decisions.

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 support@polygon.io or by filling out this form.

11. Security.

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. Specifically, at Polygon we maintain a robust information security program, institute security controls with 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.

If you use our Services outside of the United States, you understand that we may collect, process, and store your Personal Information in the United States and other countries.

12. Data Retention.

We retain your 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 in order to comply with our legal obligations and to allow for fraud monitoring, detection, and prevention activities. We also keep Personal Data to comply with our contractual commitments with the applicable financial exchanges, securities information processor, and other third party suppliers of information concerning financial markets. 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.

13. International Transfers.

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.

14. Links to Third-Party Websites.

The security of your information is important to us. We use reasonable administrative, technical, and physical procedures, practices, and safeguards designed to protect personal information we collect from unauthorized access, use, alteration, exfiltration, or destruction. Although we work hard to ensure the integrity and security of our systems, it must be recognized that no information system is 100% secure and, therefore, we cannot guarantee the security of such information. Outages, attacks, human error, system failure, unauthorized use, or other factors may compromise the security of user information at any time.

15. Children's Privacy.

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.

16. Contact Us.

If you have any questions or concerns about our Privacy Policy, please contact us via email at support@polygon.io or by filling out this form.