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MARKETFRAMEWORK, LLC

PRIVACY POLICY

Effective: July 2026

1. Overview

MarketFramework, LLC, together with its affiliates (collectively, "MarketFramework," "we," "us," or "our"), respects your privacy and is committed to protecting the information we hold about you. If you have questions, comments, or concerns about this Privacy Policy or our processing of your information, please see the "Contact Information" section at the end of this Privacy Policy.

This Privacy Policy explains our practices with respect to information we collect and process in connection with your relationship with us. This includes information we collect through, or in association with, our website with a home page located at https://www.marketframework.com/, together with all related news, market commentary, analysis, research, video, newsletter, and other content and services we may offer from time to time through that website, our social media presence, mobile applications, or otherwise through your interactions with us (collectively, the "Services").

The MarketFramework Services are general-audience news, market commentary, and information services. Certain content and features within the Services are made available in connection with, and may direct you to, the products and services of our affiliated companies, including MyFunded Futures LLC. Where you elect to engage with an affiliated company's products or services, that engagement may be governed by the separate privacy notice and terms of that affiliated company, as described further in the "Affiliated Services and Third-Party Links" section below.

MarketFramework's United Kingdom ("UK") representative is DataRep, 107-111 Fleet Street, London, EC4A 2AB, United Kingdom. MarketFramework's European Union representative is DataRep, located at The Cube, Monahan Road, Cork, T12 H1XY, Republic of Ireland. This Privacy Policy further explains the manner in which MarketFramework collects, uses, and maintains Personal Data of individuals based in the UK and the EU, as required under the General Data Protection Regulation 2016/679 ("GDPR") or the GDPR and the Data Protection Act 2018, as applicable.

Please review the following to understand how we process and safeguard your data. By using any of the Services and/or by voluntarily providing us with your data, you acknowledge that you have read and understand the practices contained in this Privacy Policy. This Privacy Policy may be revised from time to time, so please ensure that you check this Privacy Policy periodically to remain fully informed.

2. Related Notices

This Privacy Policy should be read together with our Cookie Policy, which describes in detail the cookies and similar tracking technologies we use, and which is available at https://www.marketframework.com/cookie-policy. California residents should also refer to the "Your California Privacy Rights" section of this Privacy Policy. To access this Privacy Policy in other languages, please contact us using the contact details below.

3. What Information Do We Collect?

We collect certain information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household ("Personal Data") through the Services, including:

  • When you provide it to us directly, including by creating an account, subscribing to a newsletter or other content, or registering for an event;
  • Automatically through logging and analytics tools, cookies, pixel tags, web beacons, and similar technologies, and as a result of your use of and access to the Services; and
  • From third-party sources, including service providers, advertising and analytics partners, and other third parties from time to time.

You have choices about certain information we collect. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide any aspect of our Services, you may not be able to use those Services. In addition, as noted below in the "Your Choices" section, it is possible to change your browser settings to block the automatic collection of certain information.

Finally, we may collect data that is not identifiable to you or otherwise associated with you, such as aggregated data, and is not Personal Data. To the extent this data is stored or associated with Personal Data, it will be treated as Personal Data; otherwise, the data is not subject to this Privacy Policy.

Information You Share With Us

We collect Personal Data from you when you provide it to us, including through creating an account, subscribing to newsletters, commentary, or other content, registering for or attending an event, participating in a survey or promotion, or contacting us with questions or comments. For example, if you create an account or subscribe to the Services, we may collect your name, email address, phone number, physical address, billing address, and payment information, and we may collect your username, password, and content preferences.

Information Collected Automatically or Indirectly from You

When you browse or use the Services, we and our service providers utilize commonly used logging and analytics tools to collect information about your use of the Services, including how you navigate and move around the Services, the articles and content you view, and the links you click.

We also use cookies, pixel tags, web beacons, and similar tracking technologies to operate and secure the Services, to personalize and enhance your experience, to analyze usage of the Services, and-subject to your choices and applicable law-to deliver content and advertising that may be of interest to you, including on other websites and platforms. For more information, please see the "Cookies and Web Tracking" section of this Privacy Policy and our separate Cookie Policy.

Information collected automatically includes the software and hardware attributes of the device you use to access the Services, unique device identifiers, regional and language settings, performance data about the Services, network provider, and IP address (a number assigned to your device when you use the Internet). In addition, information is collected passively in the form of log files that record activity on the Services. For example, log file entries and analytics data are generated every time you visit a particular page, and track the dates and times that you use the Services, the pages you visit, the amount of time spent on specific pages, the website from which you entered our Services, and other similar usage information.

Information Obtained from Third Parties

We may receive Personal Data from third parties that we have engaged to provide services to us, such as payment processors, analytics providers, advertising partners, and other vendors from time to time, as well as from social media platforms when you interact with our content on those platforms. We may combine this information with the Personal Data we collect directly from you.

4. Legal Bases for Processing

We process Personal Data for, or based on, one or more of the following legal bases:

  • Your Consent. We may process your information if you have provided us with consent to use your Personal Data for a specific purpose. You have the right to revoke your consent at any time.
  • Performance of a Contract. We may process Personal Data to enter into, or perform under, the agreement between us, including providing subscriptions or other content you request.
  • Legitimate Interests. We may process Personal Data for our legitimate interests, including operating and improving the Services; analyzing and understanding how the Services are used; marketing our content and services; and, to the extent necessary and proportionate, ensuring network and information security, detecting fraud, and pursuing legal compliance.
  • Compliance with Legal Obligations and Protection of Individuals. We may process Personal Data to comply with the law and our legal obligations, as well as to protect you and other individuals from certain harms.

By way of illustration, the principal purposes for which we process Personal Data, and the legal basis on which we rely for each, are as follows:

Sending you (personalized) marketing email and text communications - we obtain your consent.

Creation of your account to use the Services - we obtain your consent.

Management of your account on the Services - performance of the Terms of Use of the Services.

Management of our commercial relationship - performance of the Terms of Use of the Services.

Management of requests and complaints - our legitimate interest in responding to requests and complaints.

Operating, maintaining, securing, and improving the quality of the Services and their content - our legitimate interest in operating, maintaining, securing, and improving the Services.

Analytics and behavioral advertising on and off the Services - your consent and/or our legitimate interests, as applicable under local law.

Management of litigation and disputes - our legitimate interest to enforce our rights and those of our users and partners.

Management of requests from authorities - compliance with a legal obligation.

5. How Do We Process Personal Data?

Operational Uses

We process Personal Data as part of our operations, which include:

  • Providing you with content, information, and services tailored to your requests, and responding to inquiries;
  • Operating, maintaining, securing, and improving the quality of the Services and the content we make available through the Services;
  • Communicating with you by email and text message (SMS, MMS), in each case with your consent where required by applicable law;
  • Personalizing content and, subject to your choices and applicable law, delivering and measuring advertising on and off the Services;
  • Debugging to identify and repair errors that impair existing intended functionality;
  • Undertaking internal research for technological development and demonstration;
  • Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
  • Complying with applicable laws, regulations, rules, and requests of relevant law enforcement and other governmental agencies;
  • Enforcing our Terms of Use; and
  • For other purposes, as permitted or required by law.

Sharing of Personal Data

Some of the above processing involves sharing Personal Data with third parties, including service providers and other partners.

  • We share Personal Data with third parties when you authorize us to do so to effectuate transactions and provide the Services;
  • We share Personal Data with certain affiliated companies within our group of companies, including MyFunded Futures LLC, as described below;
  • We share Personal Data with our service providers, including hosting, payment, analytics, advertising, and security vendors, so that they may provide services to us or on our behalf;
  • Subject to your choices and applicable law, we share certain information (such as online identifiers and information about your interactions with the Services) with advertising and analytics partners to provide and measure advertising, including cross-context behavioral advertising; and
  • We share Personal Data with government agencies or regulators when permitted or required to do so by law; in response to a request from a law enforcement agency or any regulatory authority; and/or to protect the integrity of the Services or our interests, rights, property, or safety, and/or that of our users and others.

Where we permit certain third parties (such as online advertising services, advertising networks, and social networks) to collect Personal Data via automated technologies on the Services for cross-context behavioral advertising purposes, these disclosures may be considered a "sale" or "sharing" of Personal Data under certain U.S. state privacy laws. Please see the "Your California Privacy Rights," "Your Other U.S. Privacy Rights," and "Your Choices" sections below for information about how to opt out.

Affiliated Services and Co-Branded Content

MarketFramework operates as part of a group of affiliated companies. We may offer co-branded content, newsletters, events, contests, sweepstakes, or other promotions together with an affiliated company or a third party ("Co-Branded Services"). These Co-Branded Services may be hosted by MarketFramework or by the affiliated company or third party. By virtue of these relationships, we may share the information you submit in connection with a Co-Branded Service with the relevant affiliated company or third party, and their use of your information will be governed by their own privacy notice.

Where the Services direct you to, or you elect to engage with, the products or services of an affiliated company (including MyFunded Futures, LLC), the information you provide directly to that affiliated company in connection with its products or services is governed by that company's separate privacy notice and terms, and not by this Privacy Policy.

6. Your Rights Regarding Personal Data

You have certain rights regarding the collection and processing of Personal Data. You may exercise these rights, to the extent they apply to you, by contacting us at the information provided at the end of this Privacy Policy, or by following instructions provided in this Privacy Policy or in communications sent to you.

Accessing, Modifying, Rectifying, and Correcting Collected Personal Data

We strive to maintain the accuracy of any Personal Data collected from you, and will try to respond promptly to update our records when you tell us the information in our records is not correct. However, we must rely upon you to ensure that the information you provide to us is complete, accurate, and up to date, and to inform us of any changes. Please review all of your information carefully before submitting it to us, and update your account with any changes or corrections. Depending on the laws that apply to you, you may obtain from us certain Personal Data in our records. We reserve the right to deny access as permitted or required by applicable law.

7. Your California Privacy Rights

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the "CCPA"), provides you with certain rights regarding your Personal Data, subject to certain exceptions. These rights include the right to know, the right to access, the right to correct, the right to delete, the right to opt out of the "sale" or "sharing" of Personal Data, and the right to limit the use and disclosure of sensitive personal information, as well as the right not to be discriminated against for exercising your rights.

We disclose certain Personal Data (such as online identifiers and internet activity information) to advertising and analytics partners for cross-context behavioral advertising, which may be considered a "sale" or "sharing" under the CCPA. You may opt out of these activities through the cookie consent banner on our website, by broadcasting a recognized opt-out preference signal (such as the Global Privacy Control) through your browser, or by contacting us using the details below.

8. Your Other U.S. Privacy Rights

If you are located in Colorado, Connecticut, Delaware, Iowa, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Texas, Utah, or Virginia (or another state with a comprehensive consumer privacy law), you have certain rights regarding your Personal Data. These rights are not absolute, and we may decline your request as permitted by law. You may also appeal any denial of your request in the same manner through which you submitted it. Subject to applicable law, you may have the following rights:

  • Right to Access and Portability. You have the right to access your Personal Data and/or receive a copy of the Personal Data we have collected about you.
  • Right to Correct. You have the right to correct inaccurate or outdated Personal Data that we have collected about you.
  • Right to Delete. You have the right to delete the Personal Data we have obtained from or about you, with certain exceptions.
  • Right to Opt Out of Targeted Advertising. You have the right to opt out of the processing of your Personal Data for targeted advertising.
  • Right to Opt Out of Sales. You have the right to opt out of the sale of your Personal Data to third parties.
  • Right to Opt Out of Profiling. You have the right to opt out of profiling in furtherance of decisions that produce legal or similarly significant effects, as defined by applicable state law.
  • Right to Opt In for Sensitive Data Processing. To the extent we process any of your sensitive Personal Data, you have the right to opt in, or to limit such processing, as required under applicable state law.
  • Right to Non-Discrimination. If you exercise any of your rights, you have the right to be treated the same as a consumer who does not exercise any rights.

9. Your Canadian Privacy Rights

Residents of Canada are permitted to request and obtain from us information respecting the existence, use, and disclosure of their Personal Data, as well as access to that information (subject to certain exceptions pursuant to applicable laws). Without limiting the above, residents of Canada will, upon request, be informed of whether we hold Personal Data about them; be provided with an account of third parties to which we have disclosed their Personal Data; be able to challenge the accuracy and completeness of their Personal Data and have it amended as appropriate; and be provided with information about our policies and practices with respect to the management of Personal Data.

10. Your EU, UK, and Swiss Privacy Rights

If you are located outside the United States, we transfer Personal Data for processing in the United States. Under the GDPR, we are considered a "controller" of the Personal Data. By using the Services outside the United States, you acknowledge that we will transfer your data to, and store your Personal Data in, the United States, which may have different data protection rules than in your country, and that Personal Data may become accessible as permitted by law in the United States, including to law enforcement and/or national security authorities. We rely on our third-party service providers' own data transfer mechanisms, which may include the EU-U.S. Data Privacy Framework, standard contractual clauses, or other appropriate safeguards recognized under applicable law. We encourage EEA, Swiss, and UK visitors to review the privacy policies of our third-party service providers for further information about how they handle international data transfers.

Under the GDPR, you may have the following rights with respect to your Personal Data:

  • Right to Access and Portability. The right to access your Personal Data and/or receive a copy of the Personal Data we have collected about you in a portable format.
  • Right to Correct. The right to update and correct inaccuracies in your Personal Data.
  • Right to Object. The right to object to the continued processing or use of your Personal Data in certain situations, including for direct marketing.
  • Right to Erasure. The right to have your Personal Data blocked, anonymized, or deleted, as appropriate in certain situations.
  • Right to Complain. The right to complain to a supervisory authority.
  • Right to Withdraw Consent. Where you have provided consent to use your Personal Data, the right to withdraw that consent at any time. Withdrawing consent will not affect the lawfulness of processing carried out before the withdrawal.

To make any of the requests listed above, please contact DataRep through its online webform at www.datarep.com/data-request. We may ask you to provide additional information for identity verification purposes.

11. Marketing

We may use your Personal Data to send you updates about our content and services. Where permitted, we rely on our legitimate interest to send you marketing information; where consent is required, we will ask for it separately and clearly. Our Services also collect certain information automatically using cookies and other automated technologies; for more information, please see the "Cookies and Web Tracking" section below and our Cookie Policy. If you do not wish to be contacted by us, you can follow the unsubscribe instructions that accompany any marketing communication or contact us using the details in the "Contact Information" section. If you opt out of such communications, we may still contact you about your account or the Services. We will never sell or share your Personal Data with organizations outside our group of companies for their own marketing purposes without your consent.

12. Cookies and Web Tracking

Cookies are small text files that are placed on your device when you use our Services. We and our service providers and partners use cookies, pixel tags, web beacons, and similar technologies to operate and secure the Services, to remember your preferences, to analyze how the Services are used, and, subject to your choices and applicable law, to deliver and measure content and advertising, including cross-context behavioral advertising. Where required by applicable law, we will ask for your consent before placing non-essential cookies on your device. For a detailed description of the categories of cookies we use and how to manage them, please see our separate Cookie Policy at https://www.marketframework.com/cookie-policy.

Most web browsers allow you to control cookie settings, typically under the "Help," "Settings," or "Privacy" menu. You may also exercise choices about advertising cookies through the cookie consent banner on our website (labeled "Cookie Preferences" or "Cookie Settings") or through industry opt-out tools such as those offered by the Digital Advertising Alliance (optout.aboutads.info) and the Network Advertising Initiative (optout.networkadvertising.org). If you disable or delete certain cookies, you may not be able to use certain features of the Services.

13. Protecting Personal Data

We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of Personal Data. Those safeguards include the encryption of Personal Data where we deem appropriate, steps to ensure Personal Data is backed up and remains available in the event of a security incident, and periodic testing, assessment, and evaluation of the effectiveness of our safeguards. However, no method of safeguarding information is completely secure. While we use measures designed to protect Personal Data, we cannot guarantee that our safeguards will be effective or sufficient, and you should be aware that Internet data transmission is not always secure.

14. Retention of Personal Data

We retain Personal Data for as long as you are using the Services, and to the extent we deem necessary to carry out the processing activities described above, including compliance with applicable laws, regulations, rules, and requests of relevant law enforcement and other governmental agencies, and to the extent we reasonably deem necessary to protect our rights, property, or safety and those of our users and other third parties.

15. Your Choices

You have choices about certain information we collect about you, how we communicate with you, and how we process certain data. When you are asked to provide information, you may decline to do so; but if you choose not to provide information that is necessary to provide some of our Services, you may not be able to use those Services. In addition, it is possible to change your browser settings to block the automatic collection of certain information.

Communications Opt-Out

You may opt out of receiving communications from us at any time through a given communications channel by following the opt-out link or other unsubscribe instructions provided in any email message received, or by contacting us as provided at the end of this Privacy Policy. If you wish to opt out by email, please include "Opt-Out" in the subject line, and include your name and the email address you used to sign up for communications in the body of the email.

Advertising and Cross-Context Behavioral Advertising

You may opt out of the "sale" or "sharing" of your Personal Data and of targeted or cross-context behavioral advertising through the cookie consent banner on our website (labeled "Cookie Preferences" or "Cookie Settings"), by broadcasting a recognized opt-out preference signal (such as the Global Privacy Control), or by using the industry opt-out tools described in the "Cookies and Web Tracking" section above. We honor recognized opt-out preference signals where required by applicable law.

Automated Decision-Making

MarketFramework does not engage in automated decision-making that produces legal or similarly significant effects in connection with the Personal Data it collects.

16. Other Important Information About Personal Data and the Services

Children

The Services are general-audience services and are not directed to, and we do not knowingly collect Personal Data from, children under 16 years of age. If you believe that a child under 16 has provided us with Personal Data, please contact us using the details below, and we will take appropriate steps to delete such information.

Business Transfer

We may, in the future, sell or otherwise transfer some or all of our business, operations, or assets to a third party, whether by merger, acquisition, or otherwise. Personal Data we obtain from or about you via the Services may be disclosed to any potential or actual third-party acquirers and may be among those assets transferred.

International Use

Your Personal Data will be stored and processed in the United States. If you are using the Services from outside the United States, by your use of the Services you acknowledge that we will transfer your data to, and store your Personal Data in, the United States, which may have different data protection rules than in your country.

Affiliated Services and Third-Party Links

This Privacy Policy does not apply to information collected by any third-party services or websites linked from the Services, including the products and services of affiliated companies that are governed by their own privacy notices. Any such collection or receipt of Personal Data is subject to those third parties' privacy notices and terms of use, and under no circumstances are we responsible or liable for any third party's compliance therewith.

17. Modifications and Updates to this Privacy Policy

This Privacy Policy replaces all previous disclosures we may have provided to you about our information practices with respect to the Services. We reserve the right, at any time, to modify, alter, and/or update this Privacy Policy, and any such modifications, alterations, or updates will be effective upon our posting of the revised Privacy Policy. Your continued use of the Services following our posting of any revised Privacy Policy will constitute your acknowledgement of the amended Privacy Policy.

18. Applicability of this Privacy Policy

This Privacy Policy is subject to any agreements, including our Terms of Use and other agreements that govern your use of the Services. This Privacy Policy applies regardless of the means used to access or provide information through the Services.

19. Contact Information

If you have any questions or concerns about this Privacy Policy and/or how we process Personal Data, please contact [email protected].