Privacy Policy

Introduction

Market Memo (“Company,” “Owner,” “we,” “us,” or “our”) respects your privacy and is committed to protecting the personal information you share with us. This Privacy Policy describes how we collect, use, store, share, and protect your personal information when you access our websites, services, platforms, or interact with us. By using our Sites or Services, you agree to this Privacy Policy. If you do not agree, you must discontinue your use of our Sites and Services.

Data Collection

Complete details on each type of Personal Data collected are provided in the dedicated sections of this privacy policy or by specific explanation texts displayed prior to the Data collection.

• Personal Data may be freely provided by the User or collected automatically as Usage Data when using this Application.
• Unless specified otherwise, all Data requested by this Application is mandatory, and failure to provide this Data may make it impossible for this Application to provide its services.
• Any use of Cookies or other tracking tools by this Application or third-party services used by this Application serves the purpose of providing the Service required by the User.
• Users are responsible for any third-party Personal Data obtained, published, or shared through this Application and confirm that they have the third party's consent to provide the Data to the Owner.

Mode and Place of Processing the Data

Methods of Processing

The Owner takes appropriate security measures to prevent unauthorized access, disclosure, modification, or unauthorized destruction of the Data. Data processing is carried out using computers and IT-enabled tools, following organizational procedures strictly related to the purposes indicated.

In addition to the Owner, Data may be accessible to certain persons involved in the operation of this Application (administration, sales, marketing, legal, system administration) or external parties (such as third-party service providers, mail carriers, hosting providers, IT companies, communications agencies), appointed as Data Processors by the Owner.

Legal Basis of Processing

The Owner may process Personal Data relating to Users if one of the following applies:

• Users have given their consent for one or more specific purposes.
• Provision of Data is necessary for the performance of an agreement with the User.
• Processing is necessary for compliance with a legal obligation to which the Owner is subject.
• Processing is carried out in the public interest or in the exercise of official authority vested in the Owner.
• Processing is necessary for the legitimate interests pursued by the Owner or by a third party.

Place

The Data is processed at the Owner's operating offices and any other places where processing parties are located. Data transfers may involve transferring the User's Data to a country other than their own. Users can inquire about security measures taken for such transfers by contacting the Owner.

Retention Time

Personal Data shall be processed and stored for as long as required by the purpose they have been collected for. Specifically:

• Data collected for contract performance shall be retained until the contract is fully performed.
• Data collected for legitimate interests shall be retained as long as needed to fulfill such purposes.
• Data may be retained longer if required for legal obligations or upon order of an authority.

Once the retention period expires, Personal Data shall be deleted. Rights to access, erasure, rectification, and portability cannot be enforced after the expiration of the retention period.

The Rights of Users

Users have the right to:

• Withdraw consent at any time.
• Object to the processing of their Data.
• Access their Data and obtain disclosure about its processing.
• Verify and seek rectification of inaccurate Data.
• Restrict the processing of their Data.
• Have their Personal Data deleted.
• Receive their Data and have it transferred to another controller.
• Lodge a complaint with a data protection authority.

Right to Object to Processing

Where Data is processed for public interest or legitimate interests, Users may object to processing by providing a justification related to their situation. If Data is processed for direct marketing, Users can object at any time without providing justification.

How to Exercise These Rights

Requests to exercise User rights can be directed to the Owner through the contact details provided in this document. Requests are free of charge and will be addressed within one month.

Additional Information About Data Collection and Processing

Legal Action

User Personal Data may be used for legal purposes by the Owner in court or in the stages leading to possible legal action arising from improper use of this Application or related Services.

System Logs and Maintenance

For operational and maintenance purposes, this Application and third-party services may collect logs and other Data (such as IP Address).

Information Not Contained in This Policy

More details concerning Personal Data collection or processing may be requested from the Owner at any time.

"Do Not Track" Requests

This Application does not support "Do Not Track" requests. Users should check third-party privacy policies for compliance with "Do Not Track" settings.

Changes to This Privacy Policy

The Owner reserves the right to update this Privacy Policy at any time. Users are encouraged to check this page frequently, referring to the last modification date at the bottom.

If changes affect processing activities based on User consent, new consent will be collected where required.