Prometheum
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Disclosures

Privacy Policy

Prometheum Ember ATS, Inc. 

Privacy Policy 
Prometheum Ember ATS, Inc. (“ProATS”, ''we”,  ''our”, and/or “us”) values the privacy of individuals who use our applications or services that link to this Privacy Policy (collectively, our “Services”).  This privacy policy (the “Privacy Policy”) explains how we collect, use, and disclose personal information from users of our Services.  

Applicability
By using our applications and services (“Services”), you voluntarily are providing your personally identifiable information to us and consent to the collection and use of such personally identifiable information as set for in this Privacy Policy.  Beyond this Privacy Policy, your use of our Services is also subject to our Terms of Service
If you do not agree to the terms of this Privacy Policy or our Terms of Service, then do not provide us with any information and do not utilize our Services.
 
Modification
We may modify this Privacy Policy at any time so please review this policy from time to time. If you have questions regarding this Privacy Policy please contact us at [email protected]

Information We Collect 
We may collect a variety of personally identifiable information from or about you or your devices from various sources, as described below. 
  
A. Information You Provide to Us 
 
Registration and Profile Information.  When you register for an account to use our Services, we ask you for your personally identifiable information, including your name, email address, phone number, residential address, ProATS password, date of birth, social security number, employment status, employer name, job description, annual income, net worth, any identify documents(e.g., driver’s license, etc.), information on your trusted contacts (name and phone number, email, address, relationship), affiliations with companies and/or brokerage, and information on whether you or a family member are a senior military, governmental, or political official.

Communications.  If you contact us directly, we may receive personal information about you.  For example, when you contact us to learn more about our Services or for support, we will receive your name, email address, and the contents of your message.  If you subscribe to our marketing communications, we will receive your name and email address. 
  
Careers.  If you decide to apply for a job with us, we will collect the personal information you provide to us as part of your job application, such as your contact information and other information you submit with your application and/or include on your resume.  If you apply for a job with us through a third-party platform , we will collect the personal information you make available to us through such third-party platform. 
  
B. Information We Collect When You Use Our Services   

Use of our Services.  When you use our Services, we collect the personal information you provide to us.  For example, when you make a trade through ProATS we will collect information regarding your trade, such as the date and amount of the trade.  We will also collect information regarding your trade history, such as a record of your orders, positions, and related information, and any other information you provide to us. 

Location Information.  When you use our Services, we may infer your general location information.  For example, your IP address may indicate your general geographic region. 
  
Device Information.  We receive information about the device and software you use to access our Services, including internet protocol (IP) address, device type, and operating system version. 

Usage Information.  To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with them, such as the length of time you spend on a page, objects you click on, and the dates, times, and lengths of your sessions.  When we send you emails, we may track whether you open them to learn how to deliver a better customer experience. 

Analytics Partners.  We use analytics services such as Google Analytics to collect and process certain analytics data.  These services may also collect information about your use of other websites, apps, and online resources.  You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/ and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout

Information from Cookies and Similar Technologies.  We and our third-party partners may collect information using cookies, pixel tags, or similar technologies.  Our third-party partners, such as analytics partners, may use these technologies to collect information about your online activities over time and across different services.  Cookies are small text files containing a string of alphanumeric characters.  We may use both “Session” cookies, which disappear after you close your browser, and “Persistent” cookies which remain after you close your browser and may be used by your browser on subsequent visits to our Services. Cookies enable a website to recognize you on your return, remember your preferences and provide tailored services to you. Cookies will not contain information that will enable us to contact you via telephone, e-mail, or other means. To manage the Cookies that apply to our site, please review the settings.

In addition to the above uses, we may use your information for the purpose of conducting business with you and managing our relationship with you. The information collected also is used to provide a record of communications between ProATS and visitors to our site and to comply with any applicable legal and/or regulatory requirements.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings.  Please note that if you delete or choose not to accept cookies from the Services, you may not be able to utilize the features of the Services to their fullest potential. 
  

C. Personal Information We Receive from Third Parties   

Partners.  We may receive personal information about you from third parties and combine it with other personal information we have about you. 
  
How We Use the Personal Information We Collect 

We use the personal information we collect:   
  • To provide, maintain, debug, improve, and enhance our Services; 
  • To understand and analyze how you use our Services, and develop new products, services, features, and functionality; 
  • To understand and analyze usage patterns; 
  • To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support; 
  • To send you push notifications and/or text messages; 
  • To generate de-identified and aggregated data for any lawful purpose; 
  • For marketing purposes, such as developing and providing promotional and advertising materials that may be useful, relevant, valuable, or otherwise of interest to you; 
  • To find and prevent fraud, and respond to trust and safety issues that may arise; 
  • For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and 
  • For other purposes for which we provide specific notice at the time the personal information is collected. 
  
How We Share the Personal Information We Collect 
We do not share or otherwise disclose personal information we collect from or about you except as described below or otherwise disclosed to you at the time of the collection. 
  
Affiliates.  We may share personal information we receive with our affiliates for any of the purposes described in this Privacy Policy. 
  
Vendors and Service Providers.  We may share any personal information we receive with vendors and service providers retained in connection with the provision of our Services. 
  
Digital Asset Securities Trading.  We will provide information regarding your trade or other account information as required to settle your trade.
  
Marketing.  We do not rent, sell, or share personal information about you with non- affiliated companies for their direct marketing purposes unless we have your permission. 
  
Analytics Partners.  We may use analytics services such as Google Analytics.  These services may also collect information about your use of other websites, apps, and online resources.  You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout
  
As Required by Law and Applicable Regulations.  We may access, preserve, and disclose your personal information if we believe doing so is required or appropriate to: (a) comply with applicable laws, regulations and rules, and requests of law enforcement, regulatory and other governmental agencies; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. 

Aggregate Information. We may share in aggregate, statistical form, non-personal information regarding the visitors to the Site, traffic patterns, and site usage with our partners and affiliates.

Merger, Sale, or Other Asset Transfers.  We may transfer your personal information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. 
  
Consent.  We may also disclose your personal information with your permission. 
  
Your Choices 
  
Marketing Communications.  You can unsubscribe from our promotional emails via the link provided in the emails.  Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us. 

Do Not Track.  There is no accepted standard on how to respond to Do Not Track signals, and we do not respond to such signals. 

Third Parties. Our Services may contain links to other websites, products, or services that we do not own or operate.  We are not responsible for the privacy and advertising practices of these third parties.  Please be aware that this Privacy Policy does not apply to your activities on these third-party services or any personal information you disclose to these third parties.  We encourage you to read their privacy policies before providing any personal information to them. 


Safeguards
ProATS is aware that customer information and records can be compromised in a variety of ways. Intrusions are generally accomplished through the theft of the login credentials of a customer or firm employee.  Accounts can also be breached through fake electronic instructions (e.g., email requests for funds transmittals). ProATS has technical controls to protect Firm software and hardware that stores and processes data, as well as the data itself. We have a defense in depth strategy, this concept involves multiple layers of security controls that are placed throughout the firm’s Information Technology system. Access to the Firm’s network is restricted to authorized users only. Associated persons are granted access to the Firm’s systems based on the individual’s function with the Firm. Infrastructure and network level access and changes are logged and monitored by ProATS staff. ProATS also has a system of alerts and notifications for issues that may arise and maintains logs for Incident Management. Only the CEO or CTO or his/her designee can cause changes to network devices. Access to administrative functions is controlled by the CTO. The trading system components can only be updated by the CTO or his/her designee.
 

Security   
We make reasonable efforts to protect your personal information by using physical and electronic safeguards designed to improve the security of the personal information we maintain.  However, the security of this information depends in part on the security of the computer you use to communicate with us, the security you use to protect User IDs and passwords, and the security provided by your internet access services provider. We are not responsible for the security of your internet access services provider; you should review the security and privacy policies of your internet access services provider carefully. Information that you access via this Site may be stored on your computer during your session for your convenience. If others have access to your computer or your User ID and password, they may be able to access this information. We are not responsible for the security or privacy of information communicated to or from such a computer. Finally, you should keep any correspondence you receive relating to this Site or the Services (including, but not limited to registration information, emails, or any other information) confidential and in a safe place.    


International Visitors 
Our Services are hosted in the United States and intended for visitors located within the United States.  If you choose to use our Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing.  Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services.  By providing any information, including personal information, on or to our Services, you consent to such transfer, storage, and processing. 
  

Children’s Privacy 
We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no parts of our Services are directed to children.  If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at [email protected].

  
Pose a Question 
If you have questions about your privacy on the Services or this Privacy Policy, please contact us at [email protected] or write us at:


Prometheum Ember ATS Inc.
120 Wall Street, 25th Floor
New York, NY 10005


Please note opting out of sharing non-public information will prohibit ProATS from opening or servicing your account. 

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Prometheum
120 Wall Street, Floor 25
New York, New York 10005