Privacy

Introduction

Ascend Capital Group LLC (“Ascend,” ”Company” or “We”) respects your privacy and are committed to protecting it through our compliance with this policy.

This policy describes the types of information we may collect from you or that you may provide when you visit Ascend website(s), including any content, functionality, and services offered on or through such websites (collectively, the “Website”), and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy does not apply to information collected by:

  • Us offline or through any other means; or
  • Any third party, including through any application or content (including advertising) that may link to or be accessible from or on the Website.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it.  If you do not agree with our policies and practices, your choice is not to use our Website.  By accessing or using this Website, you agree to this privacy policy and our terms of service (“Terms”).  This policy may change from time to time.  Your continued use of this Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

If you are a California resident, please see the “Additional Disclosures for California Residents” section.  If you have any questions or wish to exercise your rights and choices, please contact us as set out below.

Privacy of Children

Our Website is not intended for children under 13 years of age.  No one age 13 or under may provide any personal information to or on the Website.  We do not knowingly collect personal information from children age 13 and under.  If you are 13 and under, do not use or provide any information on this Website.  If we learn we have collected or received personal information from a child 13 and under, without verification of parental consent, we will delete that information.  If you believe we might have any information from or about a child age 13 and under, please contact us at info@ascendcg.com.

We do not knowingly collect or sell the personal information of minors under 18 years old who are California residents.  If you are a California resident and under the age of 18, do not use or provide any information on this Website.

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our Website, including information:

  • By which you may be personally identified, such as name, postal address, e-mail address, telephone number;
  • About your internet connection, the equipment you use to access our Website, and usage details.
  • About your device, including data about the type of device or browser you use.

We collect this information:

  • Directly from you when you provide it to us.
  • Automatically as you navigate through the site.  Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies, as described below.

Information You Provide to Us

The information we collect on or through our Website may include:

  • Information that you provide by filling out forms on our Website.  This includes information provided at the time of requesting further services or subscribing to receive marketing materials and updates from us.  We may also ask you for information when you report a problem with our Website.
  • Records and copies of your correspondence (including email addresses), if you contact us.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

  • Details of your visits to our Website, including pages you visit, portions of the Website that you view and interact with, the time of day you visit or browse, and your referring and exiting pages.
  • Information about your computer and internet connection, including your device’s operating system, your internet service provider, your device’s regional and language settings, and device identifiers such as IP address.

The information we collect automatically helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:

  • Estimate our audience size and usage patterns.
  • Store information about your preferences, allowing us to customize our Website according to your individual interests.
  • Recognize you when you return to our Website.

The technologies we use for this automatic data collection may include:

  • Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer.  You may refuse to accept browser cookies by activating the appropriate setting on your browser.  However, if you select this setting you may be unable to access certain parts of our Website.  Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
  • Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website.  Flash cookies are not managed by the same browser settings as are used for browser cookies.
  • Web Beacons. Pages of our the Website may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or and for other related website statistics (for example, recording the popularity of certain content and verifying system and server integrity).

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources or you provide to us.

Third-Party Cookies. Cookies that are placed on your browsing device by a third party can be managed through your browser (as described above) or by checking the third party’s website for more information about cookie management and how to “opt-out” of receiving cookies from them.  We use Google analytics, a web analytics service.  You can prevent the storage of data relating to your use of the Website and created via the cookie (including your IP address) by Google, as well as the processing of this data by Google, by downloading and installing the browser plug-in available at https://tools.google.com/dlpage/gaoptout (requires you to install a browser add-on).

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

  • To present our Website and its contents to you.
  • To fulfill any other purpose for which you provide it.
  • To notify you about material changes to our Website Terms of privacy policy.
  • In any other way we may describe when you provide the information.

Disclosure of Your Information

We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.  We may disclose personal information that we collect or you provide as described in this privacy policy:

  • To our agents and representatives assisting Ascend with our marketing efforts, to fulfill the purpose for which you provided the information.
  • To our vendors and service providers so they can provide us with support services such as data analytics, website hosting, technical support, and information security and technology services.
  • To our subsidiaries and affiliates.
  • To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Ascend’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Ascend about our Website users is among the assets transferred.
  • To generally fulfill the purpose for which you provide it.
  • For any other purpose disclosed by us when you provide the information.

We may also disclose your personal information:

  • To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
  • To enforce or apply our Terms.

Your Choices About How We Collect Your Information

You can adjust your browser settings to enable you to stop accepting cookies or to prompt you before accepting a cookie from the websites you visit.  If you do not accept cookies, however, you will not be able to use all portions or all functionalities of the Website.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit.  Note, however, there is currently no industry consensus as to what site and app operations should do with regard to these signals.  Accordingly, unless and until the law is interpreted to require us to do so, we do not monitor or take action with respect to “Do Not Track” signals. For more information on “Do Not Track,” visit https://www.allaboutdnt.com.

Information Retention Policy

We retain personal data for as long as necessary to meet our obligations to you, and for such longer period as may be in our legitimate interests and to comply with our legal obligations.  We may also retain data from which you cannot directly be identified, for example where stored against a randomly-generated identifier so we know the data relates to a single user, but we cannot tell who that user is.  We may use this kind of data for research purposes and to help us develop and improve our Website; we take appropriate measures to ensure you cannot be re-identified from this data.

Nevada Privacy Rights

Nevada laws permit customers in Nevada to opt-out of the sale of certain kinds of personal information.  Ascend does not sell your personal information to third parties for monetary consideration to trigger the opt-out requirements under Nevada law.  If you are a Nevada resident and have questions, please contact us at info@ascendcg.com.

Additional Disclosures for California Residents

These additional disclosures for California residents apply only to individuals who reside in California.  The California Consumer Privacy Act of 2018 (“CCPA”) provides additional rights to know, delete and opt out, and requires businesses collecting or disclosing personal information to provide notice of rights California residents have and can exercise.

California Notice of Collection. We have collected personal information corresponding to the following categories enumerated in the CCPA, including within the last 12 months.

  • Identifiers, including name, address, email address, account name, and IP address associated with your account.
  • Internet activity, including history of visiting and interacting with our service, browser type, browser language and other information collected automatically.

For more information on what we collect, including the sources we receive information from, review sections titled “Information We Collect About You and How We Collect It.”  We collect and use these categories of personal information for the business purposes described in the section titled “How We Use Your Information,” including to provide and manage the Website.

Ascend does not generally sell information as the term “sell” is traditionally understood.  However, to the extent “sale” under the CCPA is interpreted to include any business purposes identified herein, we will comply with applicable law as to such activity.

Ascend discloses the following categories of information for commercial purposes:

  • Identifier categories such as your name and email; and
  • Internet activity.

We use and partner with different types of entities to assist with our management and operation of the Website.  Please review the section titled “Disclosure of Your Information” for more detail about the parties with which we share personal information.

Right to Know and Delete.  If you are a California resident, you have the right to know certain information about our data practices in the preceding 12 months.  In particular, you have the right to request the following from us:

  • The categories of personal information we have collected about you;
  • The categories of sources from which the personal information was collected;
  • The categories of personal information about you we disclosed for a business purpose or sold;
  • The categories of third parties to whom the personal information was disclosed for a business purpose or sold;
  • The business or commercial purpose for collecting or selling the personal information; and
  • The specific pieces of personal information we have collected about you.

Right to Deletion.  In addition, you have the right to delete the personal information we have collected from you. However, this is not an absolute right and Ascend may have legal grounds for keeping such data.

To exercise any of these rights, please submit a request at info@ascendcg.com.  In the request, please specify which right you are seeking to exercise and the scope of the request.  We will confirm receipt of your request within 10 days.  We may require specific information from you to help us verify your identity and process your request.  If we are unable to verify your identity, we may deny your requests to know or delete.

Right to Opt-Out.  To the extent Ascend sells your personal information as the term “sell” is defined under the CCPA, you will have the right to opt-out of the sale of your personal information by us to third parties at that time.  Currently, Ascend does not sell your personal information as defined under CCPA.

Authorized Agent.  You can designate an authorized agent to submit requests on your behalf.  However, we will require written proof of the agent’s permission to do so and verify your identity directly.

Right to Non-Discrimination.  You have the right to non-discriminatory treatment by us, should you exercise any of your rights.

Shine the Light.  Customers who are residents of California may request: (i) a list of the categories of personal information disclosed by us to third parties during the immediately preceding calendar year for those third parties’ own direct marketing purposes, and (ii) a list of the categories of third parties to whom we disclosed such information.  To exercise a request, please contact us at info@ascendcg.com.  Requests must include “California Shine the Light Request” in the first line of the description and include your name, street address, city, state, and ZIP code.  We may require additional information from you to allow us to verify your identity and are only required to respond to requests once during any calendar year.

Data Security

We have implemented measures designed to secure your personal information from accidental loss and from unauthorized access, use, alteration, and disclosure.  Unfortunately, the transmission of information via the internet is not completely secure.  Although we do our best to protect your personal information, we cannot guarantee the security of your personal information transmitted to our Website.  Any transmission of personal information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures contained on the Website.

Changes to Our Privacy Policy

Our privacy policy is periodically reviewed and amended as necessary, and may change as Ascend updates its Website or related content and functionality, or as may be needed to comply with applicable law.  If you have provided your email address to us, Ascend will endeavor to notify you of any material changes by email.  Ascend also encourages you to review this privacy policy periodically to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at:

Ascend Capital Group LLC
1775 Tysons Blvd, 5th Floor
Tysons, VA 22102
info@ascendcg.com.