Privacy Policy

Updated: 02/06/2025

Monark Markets, Inc. through its affiliated companies, including MMM Securities LLC, Monark Capital Management LLC, and other related entities (collectively referred to as “Monark Markets,” “we,” or “us”), provides access and services to broker-dealers, qualified custodians, and other regulated entities (“Customers”). For information about the services provided by each company, please visit our website at monark-markets.com (collectively the “Site”). As part of our commitment to delivering these services, we prioritize protecting your privacy concerning the personal information (“PI”) we may collect about you. We do not sell your PI to third parties; however, we may share it with affiliated and non-affiliated third parties as necessary to provide our services and as otherwise outlined in this Privacy Policy. This Notice describes our current privacy practices. For as long as we have and are required to retain your PI, we will protect it in accordance with this policy.

1. Definitions

1. “Services”: Refers to the provision of Monark Markets, the Monark Markets website, and any related documentation, as well as any other specified services or deliverables provided by Monark Markets, whether directly or through its affiliates.

2. “Agreement”: The legal agreement between you and Monark Markets. For Customers accessing the MMM ATS and platform, the Agreement refers to the “Terms of Service”, MMM Subscriber Agreement, ATS Agency Only Agreement, and any other relevant agreements and supporting documents. For Users accessing the Monark Markets website, the Agreement refers to the “Terms of Service.”

3. “Controller,” “Personal Data,” “Processor,” and “Processing”: These terms have the meanings assigned to them under applicable U.S. federal and state laws regarding privacy and data protection.

2. Data Controller

The data controller responsible for your personal data is Monark Markets, Inc., located at:

Monark Markets, Inc., 30 Wall Street, 8th Floor, New York, NY 10005, United States

For any privacy-related inquiries, you may contact us at support@monark-markets.com (Attn: Privacy).

3. Information We Collect

Monark Markets may collect various types of personal information to provide and enhance our services. The information we may collect falls into the following categories:

3.1 Information You Provide Directly

• Service Information: If you use our platform, we may collect your login credentials, contact information (such as your name, address, phone number, and email address), identification information (such as your identity card, passport details, social security number, date of birth, nationality, and gender), and any other relevant information necessary to verify your identity and maintain your account.

• Operational Information: We may collect additional information necessary for the operation of our services, including but not limited to economic, financial, and tax data (e.g., tax ID, tax status, income, and other revenues), banking and financial details, investment experience, investment activity, risk tolerance, transaction history, and any other relevant data required by applicable laws and regulations.

• Payment Information: If you engage in transactions on our platform, we may collect payment information, credit card details, bank account numbers, brokerage account numbers, and other financial data necessary to process payments.

• Communication Information: Any communication you have with us, whether through email, phone, or other channels, may be recorded and stored to assist with customer service, security, and compliance purposes.

3.2 Information We Collect Automatically

• Navigation Information: When you navigate our platform or website, we automatically collect certain information about your device and usage patterns. This includes your IP address, device type, browser type, operating system, referring URLs, and information about the pages you visit on our site.

• Cookies and Tracking Technologies: We use cookies, web beacons, and other tracking technologies to enhance your experience on our platform. These tools help us understand how you interact with our site, personalize your experience, and improve our services.

3.3 Information We Collect from Third Parties

• Third-Party Sources: We may obtain personal information from third parties, such as issuers you have authorized, financial institutions, tax authorities, fraud prevention agencies, and other entities. This information may be used to verify your identity, comply with legal obligations, and improve our services.

4. Purpose and Legal Basis for Processing

Monark Markets processes your personal information for various purposes, each with a specific legal basis:

4.1 Access and Use of the Platform and Services

• Service Management: We may process your personal information to manage and maintain your service, ensuring that you can access and use our platforms. This processing is necessary to perform the Agreement between you and Monark Markets.

• Communication: We may use your personal information to send you essential communications related to your account, transactions, and other services. This processing is based on the Agreement and, where applicable, your consent.

• Service Optimization: We may analyze your usage of our platform to improve its performance, enhance functionality, and provide you with a better user experience. This processing is based on our legitimate interests in maintaining and improving our services.

4.2 Compliance with Legal Obligations

• Regulatory Compliance: We may process your personal information to comply with various legal obligations, including anti-money laundering (AML) requirements, sanctions screening, and other regulatory mandates. This processing is necessary for compliance with applicable laws and regulations.

• Fraud Prevention and Security: We may use your information to detect, prevent, and respond to fraud, security breaches, and other harmful activities. This processing is essential for protecting our business and ensuring the security of our platform and services.

4.3 Responding to Inquiries and Requests

• Customer Support: We may process your personal information to respond to your inquiries, requests, and issues. This processing is based on your consent and our legitimate interest in providing you with efficient and effective customer service.

4.4 Data Analysis and Improvement

• Service and Product Development: We may analyze the data we collect to improve our services, develop new features, and offer more personalized experiences to our users. This processing is based on our legitimate interests in innovating and enhancing our offerings.

• Marketing and Personalization: With your consent, we may use your personal information to send you marketing communications and personalize your experience on our platform. You have the right to withdraw your consent at any time by emailing support@monark-markets.com and requesting to withdraw consent.

5. Retention Periods

Monark Markets may retain your personal data for as long as necessary to fulfill the purposes outlined in this Privacy Policy, including compliance with legal, regulatory, tax, accounting, or reporting obligations. The retention period is determined based on the following factors:

• Legal Requirements: We may retain personal data as required by law, including regulations governing financial transactions, anti-money laundering, and tax reporting.

• Business Needs: We may retain data for the duration necessary to support our business operations, including the maintenance of accurate records for auditing and dispute resolution purposes.

• User Requests: We may retain data for a longer period if requested by you or required to fulfill a specific contractual obligation.

Once your personal data is no longer needed for the purposes for which it was collected, we will securely delete or anonymize the data in accordance with applicable laws, securities regulations, and best practices.

6. Disclosure of Your Information

Monark Markets may share your personal data with the following categories of recipients:

• Affiliates and Service Providers: We may share your information with our affiliates and third-party service providers who assist us in operating our platform, processing transactions, and providing related services. These parties are contractually obligated to protect your data and use it only for the purposes specified by Monark Markets.

• Regulatory Authorities: We may disclose your personal information to governmental, judicial, or regulatory authorities as required by law or to comply with legal processes, including subpoenas and court orders.

• Business Transfers: In the event of a merger, acquisition, reorganization, or sale of assets, your personal data may be transferred to the acquiring entity or parties involved in the transaction, subject to confidentiality agreements.

• Protection of Rights: We may disclose your personal information if we believe it is necessary to protect the rights, property, or safety of Monark Markets, our users, or others. This includes exchanging information with other companies and organizations for fraud prevention and risk management.

7. Security Measures

Monark Markets is committed to protecting your personal data from unauthorized access, use, alteration, and disclosure. We may implement a variety of security measures, including:

• Encryption: We use encryption protocols to protect sensitive information during transmission and storage.

• Access Controls: We limit access to personal data to employees, contractors, and agents who need such access to perform their job duties. These individuals are bound by confidentiality obligations.

• Security Monitoring: We employ monitoring and detection systems to identify and respond to potential security threats.

• Regular Audits: We conduct regular audits and assessments of our security practices to ensure compliance with industry standards and best practices.

Despite our efforts to protect your personal data, no security measures are infallible. We cannot guarantee the absolute security of your information, and any transmission of data is at your own risk.

8. Your Rights Regarding Your Personal Information

You have the following rights concerning your personal data:

• Access: You have the right to request access to the personal information we hold about you.

• Correction: You have the right to request corrections to any inaccurate or incomplete personal information.

• Deletion: You have the right to request the deletion of your personal data, subject to certain legal exceptions.

• Objection: You have the right to object to the processing of your personal data based on legitimate interests.

• Withdrawal of Consent: Where we rely on your consent to process your personal data, you have the right to withdraw that consent at any time.

To exercise any of these rights, please contact us at support@monark-markets.com.

We will respond to your request in accordance with applicable laws.

9. Changes to This Privacy Policy

Monark Markets may update this Privacy Policy periodically to reflect changes in our practices, legal requirements, or other factors. When we make significant changes to this policy, we will notify you through the platform or by email. The date of the most recent update will be displayed at the top of this policy.

10. Contacting Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data protection practices, please get in touch with us at:

Monark Markets, Inc., 30 Wall Street, 8th Floor, New York, NY 10005, United States

Email: suppport@monark-markets.com (Attn: Privacy).