This is information that you choose to provide to us, which may include without limitation: your name, job title, company name, contact information including email, postal address and telephone number(s), social security number, occupation, income, and information from the consumer and/or credit reporting agencies among other background and other relevant information. You may or will, as applicable, provide your personal information in the following circumstances:

USING OUR SERVICES

Our provision of services to you as well as our third-party providers (e.g., clearing and custody providers) require the use of your personal information. We also use your personal information in order to monitor and analyze our business and operations including, without limitation, to comply with applicable legal and regulatory requirements and in connection with investigations and litigation.

SUBSCRIBING TO MARKETING SERVICES, NEWS, ALERTS, OR OTHER PUBLICATIONS

You can use the Sites to subscribe to Lightspeed or third-party marketing services, news, data, alerts, or other publications. We may ask you to provide personal information such, without limitation, as your name, contact details, and topics of interest. We will use this information to provide you with the content you have requested and to tailor this content to your preferences and areas of interest as well as to provide the information required by certain third-party providers of services such, without limitation, providers of data.

We may use your personal information to communicate with you about other topics that we believe may be of interest unless you withdraw your consent. You can unsubscribe from this content at any time (please see the “Opting-out of Communications” section below).

BLOGS

In some cases, our Sites allow you to comment on Lightspeed blog posts and to share content with third parties via email or social media. Personal information may be shared in any comment, and you may submit your name or email address with the comment. By sharing content on social media, you will provide Social Networks with information about your use of our Sites.

You can use our Sites to subscribe to an RSS feed or to receive email updates of our blogs by submitting your name and email address. We use this information to send you the content you request and to communicate with you in connection with our blogs. You can unsubscribe from this content at any time (please see the “Opting-out of Communications” section below).

EVENTS OR WEBINARS

You may provide your personal information, including your name and contact details, through our Sites to register for Lightspeed events and webinars. We will use this information to process the registration and contact you about any changes or updates regarding the event or webinar.

We may share your personal information with speakers or event sponsors, provided you have given your consent. We may also contact you with information about other events and other Lightspeed activities and services provided you have consented to receive such information. You can unsubscribe from this information at any time (please see the “Opting-out of Communications” section below).

CAREERS

You can use our careers site, to learn about our firm and apply for open positions by submitting a resume and other information via email. We may also receive resumes from recruitment consultants, Lightspeed employees, or other third parties.

Resumes will typically include personal information, including name, contact details, information about academic and professional qualifications and experiences, your interests, and the position at Lightspeed for which you are applying.

We will use this personal information to:

• Assess your suitability for the position for which you are applying.
• Contact you in relation to your application.
• Manage and administer our recruitment processes; and
• Provide updates on vacancies at Lightspeed which might be suitable for you, provided you have given your consent.

In the event you are not hired by our firm, we will permanently delete your resume and any other personal information held about you within six months after receiving your application unless you have given us your consent to keep this information for a longer period to inform you about future vacancies which may be of interest.

CONTACTING US BY PHONE, E-MAIL, OR OTHERWISE

When you communicate with us via our contact us page, you are asked to provide your name, email address, and phone number. We will use this information to respond to your questions and comments. We will request similar personal information to confirm your identity when you contact us by phone, email, or otherwise.

We will use your personal information to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you, provided you have given your consent, which can be withdrawn at any time.

SITE USE INFORMATION

Our web servers may collect information including the IP address of visitors to our Sites, browser type and version, time zone setting, browser plug-in types and versions, operating system, and platform.

We use this personal information for the following purposes:

• To measure the use of our Sites, including the number of visits, average time spent on a Site, pages viewed, page interaction information (such as scrolling, clicks, and mouse-overs), etc., and to improve the content we offer.
• To administer the Sites and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes; and
• As part of our efforts to keep the Sites safe and secure.

We may share with third parties this information or other data on an aggregated basis without the use of any personal information.

COOKIE POLICY

Like most websites, we may employ “cookies” or similar technologies. This Cookies Policy tells you about the use of Cookies and similar technologies on Lightspeed’s websites and other applications listed here, www.lightspeed.com and www.lightspeedinstitutional.com (the “Sites”).

When you first access the Sites from certain jurisdictions, you will receive a message advising you that cookies and similar technologies are in use. By continuing to browse the Sites, you signify that you understand and agree to the use of these technologies, as described in this Cookies Policy.

You do not have to accept cookies and consent can be withdrawn at any time (see How to Control Cookies, below). You can change your browser settings to refuse or restrict cookies, and you may delete them after they have been placed on your device at any time. If you do not accept or delete our cookies, some areas of our Sites that you access may take more time to work or may not function properly.

WHAT ARE COOKIES?

Cookies are small files containing a string of characters that we may store on your computer or mobile device when you visit the Sites. When you visit the Sites again, the cookies allow us to recognize your browser. Cookies may store your preferences and other information but cannot read data off your hard disk or read cookie files created by other sites.

We may use cookies to deliver content tailored to your interests. We may use information collected with cookies to statistically analyze usage of our Sites and to improve and customize our content and other offerings.

HOW TO CONTROL COOKIES

When you first access the Sites from certain jurisdictions, you will receive a message advising you that cookies and similar technologies are in use. By continuing to browse the Sites, you signify that you understand and agree to the use of these technologies, as described in this Cookies Policy.

You do not have to accept cookies and consent can be withdrawn at any time, although you may not be able to use certain features on the Sites. You can do this by activating the settings on your browser that allows you to refuse all or some cookies.

Please follow the links below for helpful information for the most popular browsers:

• Microsoft Internet Explorer
• Google Chrome
• Mozilla Firefox
• Apple Safari

In addition, you can exercise advertising cookie choices by visiting:

·      http://www.aboutads.info/choices/,

·      http://www.networkadvertising.org/choices/;

·      http://youronlinechoices.com/.

WEB BEACONS

As well as cookies, we use other technologies to recognize and track visitors to our Sites. A web beacon (also known as a “tracking pixel” or “clear GIF”) is a clear graphic image (typically a one-pixel tag) that is delivered through a web browser or HTML e-mail, typically in conjunction with a cookie.

Web beacons allow us, for example, to monitor how users move from one page within our Sites to another, to track access to our communications, to understand whether users have come to our Sites from an online advertisement displayed on a third-party website, to measure how ads have been viewed, and to improve Site performance.

CHANGES TO THIS COOKIES POLICY

We may occasionally amend this Cookies Policy to reflect our activities and user feedback, and we reserve the right to make changes to this Cookies Policy at any time.

The provisions contained in this Cookies Policy supersede all previous notices or policies regarding our privacy practices with respect to the Sites.

Please check the “Last Updated” legend at the top of this page to see when this Cookies Policy was last revised.

We encourage you to check frequently to see the current Cookies Policy to be informed of how we are committed to protecting your information and providing you with improved content on our Sites to enhance your experience.



CONTACT

If you have any questions or comments regarding our Cookies Policy or our Sites, please contact us using the contact us page.

We do not use technology that recognizes a “do-not-track” signal from your web browser, because we do not track users other than for aggregate statistical purposes.

If you have subscribed to or are otherwise receiving Lightspeed news, alerts, blog posts, or similar information from us by email and no longer want to receive such information in the future, you may opt-out of receiving these emails by clicking the “unsubscribe” link at the bottom of those emails you receive. Please allow ample time for us to process your request. If you are having difficulty unsubscribing, please contact us using the contact us page. Please note that even if you opt-out of receiving emails, you may still receive communications related to your interaction with us (such as confirmation of a registration or form submission) or otherwise as required by law or regulation. Also note that we may need to keep the personal information we have collected about you to respect your decision to opt-out, for record-keeping, research, and other purposes.

We will not share, rent, sell, or otherwise disclose any personal information that we collect about you through our Sites, except in any of the following situations:

• You request or consent to the release of your personal information.
• We will disclose your personal information to third-party agents, contractors, and payment processors who perform services for us or to complete or confirm a transaction or series of transactions that you conduct with us.
• We will disclose your personal information to service providers or suppliers where the disclosure will enable that party to perform business, professional or technical support for us.
• Where you have provided your consent, which can be withdrawn at any time, we will provide your personal information to other select third parties approved by Lightspeed as offering products or services relevant and useful to you. The use by and/or content of communications from any third party will be pre-approved by Lightspeed.
• We may disclose personal information about you as part of a merger, acquisition, or other sale or transfer of the assets or business of Lightspeed. In such circumstances, we will take steps to inform you of the transfer either directly or indirectly through publishing news of the transaction; and
• We may disclose personal information you have provided to comply with the law, applicable regulations, governmental and quasi-governmental requests, court orders or subpoenas, or to enforce our Terms of Use or other agreement with you; or to protect our rights, property or safety or the rights, property or safety of our users or others. We reserve the right to release information that we collect to law enforcement or other government officials, as we, in our sole and absolute discretion, deem necessary or appropriate.

• Where Personal Information is requested, we use technology designed to encrypt the information that you input before it is sent to us. In addition, we take steps to protect the user data we collect against unauthorized access. However, you should keep in mind that the Sites are run on software, hardware, and networks, any component of which may, from time to time, require maintenance or experience problems or breaches of security beyond our control. While we take steps to protect your personal information and keep it secure, you also play a role in protecting your information. You must maintain the security of your transactions and communications by not sharing your passwords and account information with any unauthorized parties. Please also be aware that despite our best intentions and the guidelines outlined in this privacy policy, no data transmission over the Internet or encryption method can be guaranteed to be 100% secure. We cannot guarantee the security of any information you transmit to us or from our Sites, and therefore you use our Sites at your own risk.

We will store your personal information, in a form that permits us to identify you, for no longer than is necessary for the purpose for which the personal information is processed. We may retain and use your personal information as necessary to comply with our legal and regulatory obligations, resolve disputes, and enforce our agreements and rights if it is not technically reasonably feasible to remove it and as otherwise described in this document. Consistent with these requirements, we will try to delete your personal information quickly upon request.

If you access a Site from outside of the United States, information that we collect about you will be transferred to servers inside the United States, which may involve the transfer of information out of your country of origin. By allowing us to collect personal information about you, you consent to such transfer and processing of your personal information.

For California residents only. We may disclose your personal information to our affiliates or other related third parties for their use in marketing to you. Pursuant to California’s “Shine the Light Act,” California residents are permitted to request information about the manner in which we share certain categories of information with third parties for their marketing use. Please send an email to info@lightspeed.com to request a copy of our disclosure pursuant to California law.

We will provide the required information to your email address in response. Please be aware that not all information sharing is covered by the “Shine the Light” requirements and only information on covered sharing will be included in our response.

For European residents only. Under European data protection law, in certain circumstances, you have the right to:

• Request access to any personal information we hold about you (“Subject Access Request”) as well as related information, including the purposes for processing the personal information, the recipients or categories of recipients with whom the personal information has been shared, where possible, the period for which the personal information will be stored, the source of the personal information, and the existence of any automated decision making.
• Obtain without undue delay the rectification of any inaccurate personal information we hold about you.
• Request that personal information held about you is deleted.
• Prevent or restrict processing of your personal information; and
• Request transfer of personal information directly to a third party where this is technically feasible.

Also, where you believe that Lightspeed has not complied with its obligation under this privacy policy or European law, you have the right to make a complaint to an EU Data Protection Authority.

You can exercise any of these rights by contacting us using the contact us page.

By choosing to visit our Sites or provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of the State of New York and the United States of America. You also agree to abide by any limitation on damages contained in our Terms of Use, or other agreements that we have with you which shall be broadly construed as being applicable to all uses of your personal information. Additionally, Lightspeed will not be responsible for any losses arising from inaccurate, deficient, inauthentic, or incomplete personal information provided to Lightspeed.

We reserve the right to make changes to this Privacy Policy at any time. The use of your information is subject to the Privacy Policy and Terms of Use in effect at the time of use. The provisions contained in this Privacy Policy supersede all previous notices or policies regarding our privacy practices with respect to the Sites.

Child Privacy

If you are under the age of majority in your home jurisdiction, please do not use or access the Sites. It is not our intention to collect or use personal information from anyone under the age of majority, and we will not knowingly do so. If we are made aware that we have collected any personal information from minors and are asked to delete such information from our databases, we will promptly do so.

Links to other websites

Our Sites may contain links to other websites. This privacy policy only addresses the use and disclosure of your personal information collected through our Sites, if any. If you choose to visit an external website linked to a Site, you will leave our Site. While we try to link only to websites that share our standards and respect for privacy, we are not responsible for the privacy practices of any third parties or the content of linked websites. We encourage you to read the applicable privacy policies and terms and conditions of such parties or websites.

If you are under the age of majority in your home jurisdiction, please do not use or access the Sites. It is not our intention to collect or use personal information from anyone under the age of majority, and we will not knowingly do so. If we are made aware that we have collected any personal information from minors and are asked to delete such information from our databases, we will promptly do so.

Our websites may contain links to other websites. This privacy policy only addresses the use and disclosure of your personal information collected through our websites, if any. If you choose to visit an external website linked to a website, you will leave our website. While we try to link only to websites that share our standards and respect for privacy, we are not responsible for the privacy practices of any third parties or the content of linked websites. We encourage you to read the applicable privacy policies and terms and conditions of such parties or websites.