VOEDX Marketplace, LLC (“we,” “our,” or “us”) is committed to protecting the privacy of personal information we collect. This Privacy Policy describes how we collect, use and disclose personal information collected from Authorized Users of the VOEDX Utility (the “Utility”), and from visitors to our website located at www.voedx.com (the “Site”). Capitalized terms used and not otherwise defined in this Privacy Policy have the meanings assigned to such terms in the VOEDX Authorized User Terms and Conditions pertaining to the Utility (the “Terms and Conditions”).

1. Scope of This Privacy Policy

This Privacy Policy applies to personal information that we collect from Authorized Users of the Utility, other than Subject Data (that is, other than data that is purchased and sold using the Utility). As set forth in the Terms and Conditions, the processing of Subject Data is governed by the terms of the VOEDX Data Processing Addendum, and not this Privacy Policy. This Privacy Policy also applies to personal information that we collect from individual visitors to the Site.

As set forth in the Terms and Conditions, only entities (such as corporations and limited liability companies) that are “consumer reporting agencies” or “furnishers” of information under the Fair Credit Reporting Act, through their Designated Representatives and Designated Users, may use the Utility. Individuals whose personal information is included in Subject Data should contact the Authorized User (consumer reporting agency or furnisher) that collected their information to exercise privacy rights. VOEDX acts only as a service provider/processor with respect to Subject Data and processes such data only on behalf of and at the direction of Authorized Users pursuant to a Data Processing Addendum.

This Privacy Policy does not apply to third-party websites, services, or applications, including payment processors we use to process transactions and external links that may appear on the Site. We encourage you to review the privacy policies of any third-party services before providing them with your information.

2. Information We Collect

We may collect the following types of information from Authorized Users: Account Information (including entity name, address, email address, phone number and other contact details, state of formation, EIN, and the names of Designated Representatives and Designated Users); Payment Information (including credit card, ACH, or other payment information processed by third-party payment processors — we do not store complete credit card numbers on our servers); Transaction Information (pertaining to Transactions completed using the Utility, including the types of Subject Data purchased and sold, counterparties, and the Subject Data Purchase Price); and Business Contact Data pertaining to Designated Representatives, Designated Users, and other personnel who interact with VOEDX.

We may collect the following from visitors to the Site: information that visitors choose to provide (for example, email address and other contact information submitted through a contact form, to request a demo, download materials, subscribe to updates, or otherwise interact with us). We may also automatically collect log data (such as IP address, device information, and browser type) and usage data regarding interactions with the Utility or the Site (such as pages viewed).

3. Cookies and Tracking Technology

We use cookies and similar technologies to maintain your login session, remember your preferences, analyze usage of the Utility and Site, and ensure security and prevent fraud. The types of cookies we use include essential cookies (required for the Utility and Site to function), analytics cookies (to understand how users interact with our services), and preference cookies (to remember your settings).

We may use third-party analytics services (such as Google Analytics) that use cookies to collect information about your use of the Utility and Site. You can control cookies through your browser settings; disabling certain cookies may limit functionality. We do not currently respond to “Do Not Track” browser signals. For EU visitors, we obtain your consent before placing non-essential cookies through our cookie banner.

4. How We Use Information

We use information collected from Authorized Users and visitors to: allow Authorized Users to open accounts; enable Sellers to offer and sell, and Buyers to offer to purchase and purchase, Subject Data; process payments to and from Authorized Users; enable delivery and receipt of Subject Data; calculate and bill Utility Transaction Fees and Preexisting Bilateral Agreement Transaction Fees; facilitate communication between Buyers and Sellers; respond to support, billing, and service issues; address technical issues; provide the Utility and its functionality; enforce the Terms and Conditions; respond to inquiries and fulfill requests from Site visitors; operate, maintain, and improve the Utility and Site; detect, prevent, or investigate security incidents, fraud, or misuse; and comply with applicable legal and regulatory obligations.

Legal Basis for Processing (GDPR): where the GDPR applies, we process personal information based on performance of a contract, compliance with legal obligations, your consent (for cookies and communications where required), and our legitimate interests (to improve our services, prevent fraud, and protect our systems), provided such interests are not overridden by your rights and freedoms.

5. Sharing of Information

We may share Transaction Information with other Authorized Users to allow them to complete Transactions using the Utility; share personal information (subject to applicable confidentiality restrictions) with affiliated and third-party service providers who provide hosting, support, billing and other business services; share personal information with affiliated and third-party licensors who license technology to us; share personal information with legal or regulatory authorities when required or to protect our legal rights; and share personal information (subject to applicable non-disclosure agreements) in connection with a sale or potential sale of our business.

Except as set forth above, we do not “sell” or “share” personal information as those terms are defined under California privacy laws. We do not sell personal information for monetary or other valuable consideration, do not share personal information for cross-context behavioral advertising, and do not sell or share personal information for marketing purposes.

6. Data Retention

We retain information that we collect for as long as reasonably necessary to fulfill the purposes outlined in this Privacy Policy or as required by law. When information is no longer needed, we securely delete or anonymize it.

7. Security Measures

We implement technical and organizational security measures to protect information, including encryption of data in transit and at rest, access controls and authentication requirements, security monitoring and incident response procedures, and employee training on data security and privacy. While we use reasonable efforts to protect information, no security system is impenetrable. If we experience a data security incident that affects your personal information, we will notify you as required by applicable law.

8. Data Subject Rights

Individuals in California and certain other states and jurisdictions have rights regarding their personal information, including the right to know, the right to access, the right to correct, the right to delete, the right to opt-out of the sale or sharing of personal information, the right to limit the use of sensitive personal information, and the right to non-discrimination for exercising these rights.

To exercise any of these rights, you may email us at privacy@voedx.com or mail us at VOEDX Marketplace, LLC, 4 May Hill Lane, Dix Hills, NY 11746. To protect your privacy and security, we will verify your identity before processing your request. You may designate an authorized agent to submit requests on your behalf. We will generally respond to verifiable requests within 45 days (with the possibility of a 45-day extension). If we deny your request, you may appeal by contacting us using the methods above.

Additional Rights for EU Residents: if you are located in the EEA, United Kingdom, or Switzerland, you also have the right to object to processing, the right to restrict processing, the right to data portability, the right to withdraw consent, and the right to lodge a complaint with your local data protection authority.

9. Children’s Privacy

Only entities that are “consumer reporting agencies” or “furnishers” under the Fair Credit Reporting Act, through their Designated Representatives and Designated Users, may use the Utility, and those individuals must be 18 years of age or older. Persons under 18 are explicitly prohibited from using the Utility. Use of the Site is not directed to children, and we do not knowingly collect personal information from children.

10. Additional Information for California Residents

Under the CCPA, as amended by the CPRA, we collect the following categories of personal information: identifiers; commercial information; internet or network activity information; professional or employment-related information; and inferences drawn from the above. We collect this information directly from you, automatically from your devices, and from your authorized representatives. We use it to provide our services and website, process transactions and payments, communicate with users, improve and develop our services, ensure security and fraud prevention, and comply with legal obligations.

We may disclose personal information to service providers, technology licensors, legal and regulatory authorities, professional advisors, and potential business transaction partners. We do not “sell” or “share” personal information as those terms are defined under California law, and have not done so in the preceding 12 months. We may collect sensitive personal information limited to account login credentials and the contents of communications, and use it only for purposes permitted under California law. We retain personal information based on business need, legal and regulatory requirements (which may require retention for up to 7 years or longer), dispute resolution, and individual requests.

11. International Data Transfers

We primarily store and process personal information in the United States. If you access the Utility or the Site from the EEA, United Kingdom, or Switzerland, your information will be transferred to, stored, and processed in the United States and other countries where our service providers operate, which may not have the same data protection laws as your jurisdiction. We implement appropriate technical and organizational security measures, and our service providers are required to implement appropriate safeguards.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will post an updated copy on the Site and update the Last Updated date at the top of this Privacy Policy.

13. Contact Us

If you have any questions about this Privacy Policy, please contact us by mail at VOEDX Marketplace, LLC, 4 May Hill Lane, Dix Hills, NY 11746 or by email at privacy@voedx.com. For EU-specific privacy inquiries, you may also contact us at the email address above.