Privacy Policy

DirectEdge ECN LLC — Online Privacy Policy Statement

("DirectEdge" refers to DirectEdge ECN LLC, and its direct and indirect subsidiaries.)

Effective Date: October 21, 2005

To whom and to what does this Online Privacy Policy apply?

This Online Privacy Policy applies to the personal information that we collect from or about you via this DirectEdge Web site (the "Site"). This Site may contain links to other Web sites, and this Online Privacy Policy does not apply to those sites. If you link to any of those sites, we recommend that you review their privacy policies. If we materially change our privacy policies or practices, we will also change this Online Privacy Policy to reflect such changes.

What personal and technical information do we collect via this Site?

This Site will collect personal information that you voluntarily provide, such as your name, address, telephone number or e-mail address. This Site may also collect information on what country you are accessing this Site from and your preferences, such as language selection; information on which pages within this Site you visit; and certain technical information regarding your computer and operating systems, such as your Internet protocol address, domain name and system configurations and settings. We will not know who you are unless you tell us.

Additionally, if you access a password protected portion of this Site, then (a) once you submit your password and enter, this Site will recognize who you are and will collect all information that you submit, including all electronic instructions (including all transaction information), and (b) any information collected about you from this Site may be associated with other identifying information that we have about you.

Does this Site use "Cookies?"

On this Site, we may use cookies (a "cookie" is a small amount of data assigned to your Internet browser and stored on your computer when you visit a Web site) or other technology to gather information about Site usage to help us improve the content, usability and functionality of this Site, and to remember certain user attributes (such as the country you are accessing this Site from and your language selection). This helps us better tailor this Site for users and better understand how many new and repeat users visit this Site, which features or pages are most popular and user browsing and usage patterns.

Additionally, if you access a password protected portion of this Site, then this Site may use cookies or other technology to help us authenticate you, store and recognize your configuration and user attributes, facilitate your navigation and entitlements throughout the Site and customize its content so that the information made available is more likely to be of interest to you.

You can set your Web browser to prompt you before you accept a cookie, accept cookies automatically or reject all cookies. However, if you choose not to accept cookies from this Site, then you may not be able to access and use all or part of this Site or benefit from the information and services which it offers.

How do we use, share and disclose personal information that we collect via this Site?

Any personal information you provide and the personalized data you create and save on the site is used to provide services to you and to inform you of products, services or other opportunities that may be available through DirectEdge. Such information and data will also be used to administer our business, the Site and our services in a manner consistent with this Online Privacy Policy, the terms and conditions that govern your use of this Site and all applicable laws, rules, regulations or other legal obligations. If you provide us with your name, address, telephone number or e-mail address, or have done so in the past, DirectEdge may contact you by telephone, mail or e-mail. E-mail or other electronic communications sent to us through the Site will be maintained in a manner consistent with our legal and regulatory requirements regarding client and public communications.

We do not rent, sell or share your personal information or personalized data to unaffiliated organizations except to provide products or services you have requested, when we have your permission, or under certain limited circumstances. For example, we provide such information to companies who work on behalf of or with DirectEdge under confidentiality agreements. These companies may use your personal information to help DirectEdge communicate with you about offers from DirectEdge. These companies do not, however, have any independent right to share this information. We also use such information to respond to subpoenas, court orders, or legal process, or to establish or exercise our legal rights or defend against legal claims. In addition we will share such information if we believe it is necessary to do so in order to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the physical safety of any person, violations of this Site's terms of use or as otherwise required by law. Finally, we may transfer information about you if DirectEdge is acquired by or merged with another company. In this event, DirectEdge will notify you before information about you is transferred and becomes subject to a different privacy policy.

How do we maintain the confidentiality and security of the personal information that we collect via this Site?

DirectEdge maintains reasonable physical, electronic and procedural safeguards that comply with federal regulations to protect personal information about you, and works with vendors and partners to protect the security and privacy of user information. In this connection, we protect your account information by placing it on the secure portion of our Web site, using firewalls and other security technology to protect our network and systems from external attacks, and requiring you to enter a unique user name and password to access your profile or account information online. Also, our servers have been enabled with Secure Sockets Layer (SSL) technology to prevent unauthorized parties from viewing the nonpublic personal information that you provide or access during a secure session (look for the padlock icon on your browser). In addition, DirectEdge limits access to personal information about you to employees and third-party service providers who we believe reasonably need to come into contact with that information to provide services to you or in order to do their jobs. We conduct periodic reviews of our business practices and procedures, examining confidentiality standards and information access in order to protect your personal information.

Can I edit and delete personal information that you collect via this Site?

If applicable, you can edit your personal information or communications preferences at any time. However, DirectEdge reserves the right to send you certain communications relating to this Site, such as service announcements or administrative messages without offering you the opportunity to opt-out of receiving them.

Whom should you contact if you have questions about this Online Privacy Policy?

If you have any questions regarding this Online Privacy Policy, or our privacy-related practices, please contact us by mail at: DirectEdge Legal Department, Privacy, 545 Washington Boulevard, 3rd Floor, Jersey City, NJ 07310.

DirectEdge may, at its discretion, monitor and review the content of all e-mail communications.