Stoa Markets, Inc. (“we,” “us,” or “our”) has prepared this Privacy Policy to explain (1) what personal information we collect, (2) how we use and share that information, and (3) your choices concerning our privacy and information practices.
1. Applicability of this Privacy Policy
We provide a neutral online venue for spot transactions in physical AI hardware between institutional buyers and sellers, together with related market data, pricing, and analytics offerings (our “Services”). This Privacy Policy applies to personal information that we collect when you visit our website(s) (including https://www.stoaexchange.com/), communicate with us, attend demos, receive marketing communications, or otherwise interact with us as a prospective customer or in a consumer capacity.
If you are a business or enterprise customer of ours, this Privacy Policy does not apply to personal information or other data and information that we process on your behalf as your service provider. Our use of such data shall instead be governed by the terms and conditions of the separate customer agreement or terms of service that you have agreed to with us. In addition, our Services are designed for businesses and are not intended for personal, family, or household use. Accordingly, we treat all personal information covered by this Privacy Policy as pertaining to individuals acting as business representatives, rather than in their personal capacity.
2. Personal information we collect
Information you provide to us:
- Account information: When you create an account to use the Services, we collect information such as your phone number, email address, password, and other similar account registration information.
- Business contact information: If you are a representative of one of our actual or prospective customers, suppliers, or business partners, we may collect personal information about you (such as your name, work email address, organization name, role, and other contact details) when entering into an agreement with your organization or otherwise during the course of our business relationship.
- Onboarding and KYB information, such as information collected as part of our know-your-business intake, verification, and screening processes, which may include names and identifiers of authorized signatories and beneficial owners; government-issued identification numbers and copies of identification documents; and residency and demographic information.
- User content, such as information, data, files, or other content that you upload, submit, or otherwise provide to or through the Services, including any inputs or materials transmitted via our Services.
- Feedback or correspondence, such as information you provide when you contact us with questions, feedback, support requests, or otherwise correspond with us.
- Usage information, such as information about how you use the Services and interact with us.
- Marketing information, such as your preferences for receiving communications about our activities, services, and publications, and details about how you engage with our communications.
- Commercial and customer relationship information, such as subscription plan, invoices, contract details, billing relationship, and customer communications.
- Other information that we may collect which is not specifically listed here, but which we will use in accordance with this Privacy Policy or as otherwise disclosed at the time of collection.
Information we obtain from third parties. We may obtain your personal information from other third parties, such as marketing partners, publicly-available sources and data providers, for the purposes of marketing products and services that may interest you, delivering personalized communications, and other similar activities. In addition, we may maintain pages on social media platforms, such as LinkedIn and other third-party platforms. When you visit or interact with our pages on those platforms, the platform provider’s privacy policy will apply to your interactions and their collection, use and processing of your personal information. You or the platforms may provide us with information through the platform, and we will treat such information in accordance with this Privacy Policy.
Automatic data collection. We and our service providers may automatically log information about you, your computer or mobile device, and your interaction over time with our Services, our website, our communications, and other online services, such as:
- Device data, such as your computer’s or mobile device’s operating system type and version, browser type, screen resolution, device type, IP address, unique identifiers, language settings, radio/network information, and general location information such as city, state, or geographic area.
- Online activity data, such as pages or screens you viewed, how long you spent on a page or screen, browsing history, navigation paths between pages or screens, information about your activity on a page or screen, access times, and duration of access, and whether you have opened our marketing emails or clicked links within them. We may use third party tools to assist with capturing online activity data.
- Email open/click information. We may use pixels in our email campaigns that allow us to collect your email address and IP address as well as the date and time you open an email or click on any links in the email that we may send to you.
We may use the following technologies for automatic data collection:
- Cookies, which are text files that websites store on a visitor’s device to uniquely identify the visitor’s browser or to store information or settings in the browser for the purpose of helping you navigate between pages efficiently, remembering your preferences, enabling functionality, helping us understand user activity and patterns, and facilitating analytics and, if applicable, online advertising.
- Local storage technologies, like HTML5, that provide cookie-equivalent functionality but can store larger amounts of data, including on your device outside of your browser in connection with specific applications.
- Web beacons, also known as pixel tags or clear GIFs, which are used to demonstrate that a webpage or email was accessed or opened, or that certain content was viewed or clicked.
3. How we use your personal information
- To provide and operate our Services. We use your personal information to provide, operate, maintain, secure, debug, troubleshoot, and improve our website and Services, including to:
- Provide, operate, maintain, secure and improve our Services.
- Provide information about our Services.
- Communicate with you about our Services, including by sending you service-related notices, announcements, updates, security alerts, and support and administrative messages.
- Respond to your requests, questions, and feedback, and manage subscriptions, contracts, invoices, and customer relationships.
- To monitor, improve, personalize, and protect our Services. It is in our legitimate business interests to improve and keep our Services safe, which includes:
- Monitoring usage, performance, latency, errors, request volume, abuse, fraud, and security incidents.
- Protecting the security of our Services.
- Preventing and detecting security threats, fraud, or other criminal or malicious activities.
- Administering content, promotion, sweepstakes, surveys, voting polls and other website features.
- Marketing and advertising. We may from time-to-time send you direct marketing communications as permitted by law, including, but not limited to, notifying you of special promotions, offers and events via email. Unless we’re required to obtain your consent to send you marketing communications, we will rely on our legitimate business interests to market to you. You may opt out of our marketing communications as described in the “Opt out of marketing communications” section below.
- For research and development. It is in our legitimate business interests to use personal information (including the personal information described in this Policy and personal information collected on behalf of our customers) to develop, analyze and improve the Services and our business. We may use certain usage data and other telemetry for research and development purposes, including to analyze and improve our Services and our business. If personal information is included, we may create aggregated, de-identified, or other anonymous data from personal information we collect. We make personal information into anonymous data by removing information that makes the data personally identifiable to you. We may use this anonymous data and share it with third parties for our lawful business purposes, including to analyze and improve our Services and promote our business.
- Compliance and protection. To comply with our legal obligations or when it is our legitimate business interests, we may use personal information to:
- Comply with applicable laws, lawful requests, and legal process, such as to respond to subpoenas or requests from government authorities.
- Protect our, your or others’ rights, privacy, safety or property (including by making and defending legal claims).
- Audit our internal processes for compliance with legal and contractual requirements and internal policies.
- Enforce the terms and conditions that govern our Services.
- Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft.
4. How we share your personal information
- Service providers. We may share your personal information with third-party companies and individuals that provide services on our behalf or help us operate our Services, such as providers that assist with hosting, cloud infrastructure, storage, databases, security, identity and business verification and compliance screening, logging, analytics, customer support, communications, customer relationship management, scheduling, billing, payment processing, professional advisory services, and other business operations.
- Authorities and others. We may disclose your personal information to law enforcement, government authorities, and private parties, as we believe in good faith to be necessary or appropriate for the compliance and protection purposes described above.
- Business transfers. We may sell, transfer, or otherwise share some or all of our business or assets, including your personal information, in connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization, financing, sale of assets, or in the event of bankruptcy or dissolution. In such a case, we will make reasonable efforts to require the recipient to honor this Privacy Policy.
- Affiliates. We may share personal information with our current and future affiliates, meaning an entity that controls, is controlled by, or is under common control with us. Our affiliates may use the personal information we share in a manner consistent with this Privacy Policy.
5. Your choices
Opt out of marketing communications. You may opt out of promotional email communications by following the opt-out or unsubscribe instructions at the bottom of the email. Please note that even if you opt out of promotional emails, we may continue to send you service-related communications, such as security, account, billing, legal, and transactional notices.
Online tracking opt-out. There are a number of ways to limit the collection of your online activity and device data through our Services, which we have summarized below:
- Blocking cookies in your browser. Most browsers let you remove or reject cookies. To do this, follow the instructions in your browser settings. Many browsers accept cookies by default until you change your settings. For more information about cookies, including how to see what cookies have been set on your device and how to manage and delete them, visit www.allaboutcookies.org.
- Using privacy plug-ins or browsers. You can block our Services from setting cookies used for interest-based ads by using a browser with privacy features or installing browser plugins like Privacy Badger, DuckDuckGo, Ghostery or uBlock Origin, and configuring them to block third party cookies/trackers.
Note that because these opt-out mechanisms are specific to the device or browser on which they are exercised, you will need to opt out on every browser and device that you use.
Do Not Track. Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. We currently do not respond to “Do Not Track” or similar signals. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
6. Where we transfer and/or store your personal information
We are based in the United States. When your data is transferred to us it will be processed in the United States and in any countries where our service providers operate their businesses. Such countries may not provide the same protections as the data protection laws where you are based. When we transfer data to these recipients, we do this on the basis of this policy, and we will ensure that relevant safeguards are in place to afford adequate protection for your personal information, and we will comply with applicable data protection laws.
7. Data Retention
We retain personal information for as long as reasonably necessary to provide the Services, maintain accounts, fulfill transactions, comply with legal obligations, resolve disputes, enforce agreements, maintain security, prevent abuse, and for other purposes described in this Privacy Policy. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of such information, the potential risk of harm from unauthorized use or disclosure of such information, the purposes for which we process it, and the applicable legal requirements.
8. Other sites, mobile applications and services
Our Services may contain links to other websites, mobile applications, and other online services operated by third parties. These links are not an endorsement of, or representation that we are affiliated with, any third party. In addition, our content may be included on web pages or in other online services that are not associated with us. We do not control third-party websites or online services, and we are not responsible for their actions. Other websites and services follow different rules regarding the collection, use, and sharing of your personal information. We encourage you to read the privacy policies of the other websites and online services you use.
9. Security practices
We use reasonable administrative, technical, and organizational measures designed to protect against unauthorized access, misuse, loss, disclosure, alteration, and destruction of personal information we maintain. Unfortunately, data transmission over the Internet cannot be guaranteed as completely secure. Therefore, while we strive to protect your personal information, we cannot guarantee the security of personal information. If we are required to notify you about a situation involving your data, we may do so by email or telephone to the extent permitted by law.
10. Children
Our Services are not directed to children under 18 years of age, and we do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18 without verification of parental consent, we will take steps to delete that information. If you believe we might have any information from or about a child under 13, please contact us using the contact information provided below.
11. Changes to this Privacy Policy
We reserve the right to modify this Privacy Policy at any time. If we make material changes to this Privacy Policy, we will notify you by updating the date of this Privacy Policy and posting it on our website. We may also provide notification of changes in another way that we believe is reasonably likely to reach you, such as via email (if you have an account where we have your contact information) or another manner through our Services. Any modifications to this Privacy Policy will be effective upon our posting the new terms and/or upon implementation of the new changes on our website or Services (or as otherwise indicated at the time of posting).
12. How to contact us
If you have any questions or concerns, you can reach us by email at [email protected].