Privacy Policy



Effective Date: October 16, 2018


1. Introduction

Kirby Stock Exchange LLC (“we”, “our” or the “Company”) cares about your privacy. We are
committed to maintaining your trust by protecting your Personal Information. This privacy policy
(the “Policy”) describes how we collect, use, disclose, and share your Personal Information in
connection with your use of the website and its subdomains.

“Personal Information” is information that relates to you and can be used to identify you as an
individual. Personal Information does not include information or data that has been aggregated or
made anonymous such that you can no longer be personally identified using any means reasonably
available to us.


2. Information We Collect

We collect different types of Personal Information in different ways depending on how you interact
with our website.

We may collect information in the following ways:

• you may provide information directly to us via our website, such as when you sign up for
an account with us or purchase content from us;
• we may collect information from you when you visit and use our website through cookies,
pixels, web beacons and similar Internet technologies;
• we may collect information about you from Google Analytics. For more information about
Google Analytics, please visit the Google data privacy information page at You may opt-out of Google Analytics
at; and
• we may collect information about you from other sources such as third party payment
processors when you purchase a product from us.

We may collect the following types of Personal Information:

• Contact Information: This may include your full name, pseudonym, and email address;
• Payment Information: This may include your credit or debit card details, bank account
information, and payment or other information required when you make a purchase. We
do not store any credit card numbers or banking information or process any payments
• Analytics Information: This may include your IP address, information about the devices
that you use to access our websites and their locations, and information about your use of
our websites and services.

We may also collect and/or generate anonymized and aggregated information from your use of our
websites and services. Anonymized or aggregated information is not Personal Information.

3. Use of Personal Information

How we use your Personal Information depends on how you interact with our website and services.
In general, we may use your Personal Information to:

• operate, maintain and improve our website and provide requested content and services,
including to process requested transactions;
• respond to comments and questions, verify permissions and provide customer service;
• send information including content purchase confirmations, security alerts and
administrative messages;
• communicate about industry news, upcoming events, new products and services, special
offers and promotions (you may unsubscribe to our newsletter at any time by clicking on
the link at the bottom of each email);
• protect, investigate, and deter against fraudulent, unauthorized, or illegal activity;
• inform you about important website related notices, such as privacy policy updates; and
• comply with our legal obligations.

4. Sharing of Personal Information

We may disclose your Personal Information to our employees and third party service providers in
order to operate, maintain and improve our website and services and to process your requested


We partner with certain third parties to collect, analyze and/or use some of the Personal
Information described in this Policy. For example:

• Third-parties that provide email functionality for users and customers who opt-in to our
• Third-parties that provide web development and hosting services for our website;
• Third-parties that provide cloud storage for backups of our data;
• Third-parties that provide other support software and services for our website;
• Third-parties that provide payment processing services for purchase transactions through
our website; and
• Third-parties bookkeeping and accounting services for our Company.

We may also disclose your Personal Information if necessary to detect, limit or prevent fraud or
security issues, to protect our rights, property and safety or those of our employees or partners, or
if required by applicable law or to respond to legal process or a request for cooperation by a
government entity or law enforcement.

In the event that we purchase, sell, transfer or acquire all or a substantial portion of a business or
its assets, such as in connection with a merger, acquisition or in the event of a bankruptcy
reorganization or liquidation, then we may also disclose or share your Personal Information in
connection with such transaction. Any recipient of information in connection with any such
transaction will be required to comply with reasonable confidentiality restrictions with respect to
your Personal Information.

We will not rent, sell or otherwise share your Personal Information with third parties for marketing
or advertising purposes.

We may disclose or use aggregated or anonymized data for analytics or research purposes.

5. Rights in Your Information: Access, Rectification, Erasure and Restriction

We value your rights to your Personal Information. In accordance with applicable law, you may
have the right to (i) request confirmation of whether we store, use or share any of your Personal
Information; (ii) obtain access to or a copy of your Personal Information; (iii) receive an electronic
copy of the Personal Information that you have provided to us, or ask us to send that information
to another company; (iv) restrict our uses of your Personal Information or object to those uses; (v)
seek correction of inaccurate, untrue or incomplete Personal Information; or (vi) request erasure
of Personal Information held about you by the Company, subject to certain exceptions prescribed
by applicable law. If you would like to exercise any of these rights, please contact us at

We will process such requests in accordance with applicable local laws.


As mentioned above, we provide a means to unsubscribe to our newsletter in our email
communications. You also have the right to opt-out of certain uses and disclosures of your
Personal Information as set out in this Policy.

Please note that we may still need to send you certain communications regarding the operation and
administration of our website and services, and you will not be able to opt out of those
communications, for example communications regarding updates to this Policy and any data
security breaches.

If you no longer desire to be contacted by us for any reason, you must terminate your relationship
with the Company by emailing us at and in which case, you may
no longer access our website or use our services.

6. Storage, Retention and International Transfers

The Company is headquartered in New Jersey, in the United States. The Personal Information we
collect from you will be stored and processed in the United States. It may be transferred to and/or
stored in other countries where our service providers maintain facilities as well. In accordance with
applicable law, we implement measures, such as standard data protection clauses to ensure that
any transferred Personal Information remains protected and secure in accordance with this Policy.
If you are located in the European Union or other regions with laws governing data collection and
use, please note that we will not transfer your Personal Information across international borders
except in accordance with applicable law.

Subject to applicable law, we will retain your Personal Information indefinitely.

7. Information Security

The security of all Personal Information provided to the Company is important to us. We take
commercially reasonable steps and employ industry standard technologies designed to ensure
appropriate technical and/or organizational measures are used to protect your Personal
Information, including against unauthorized or unlawful access and accidental loss, destruction or
damage. We employ secure socket layer technology (SSL) encryption in connection with all our
website and access to any Personal Information on our servers requires 2-factor authentication.
Any sensitive Personal Information is stored on secured servers or offline.

Unfortunately, no data transmission over the Internet or storage of information can be guaranteed
to be 100% secure. As a result, while we strive to protect your Personal Information, we cannot
ensure or warrant the security of any information that you transmit to the Company, and you do so
at your own risk.

8. Compromise of Personal Information

In the event that your Personal Information is compromised as a breach of our security, the
Company will promptly notify you in compliance with all applicable laws. Subject to applicable
law, we reserve the right to determine the form and means of providing such notifications to you.

9. Automated Processing

We do not currently use your Personal Information in such a way that any automated decisions are
made about you without any human input.

10. Children’s Privacy

Generally, our websites and services are not directed to children under the age of 16, and we do
not knowingly collect Personal Information from anyone under the age of 16. Persons between 16
and 18 years of age should ask their parents for permission before using the Internet or sending
any information about themselves to anyone over the Internet. If a parent or guardian becomes
aware that his or her child has provided us with Personal Information without parental consent, he
or she should contact us at If we become aware that a child under
16 years old has provided us with Personal Information, we will delete such information from our

11. Links to Third-Party Websites

We may display links to third party websites, including social media sites that we do not own or
operate. We provide links to these third-party sites as a convenience to you. They are not intended
as an endorsement of or referral to the linked sites or services. The linked sites services are subject
to their separate and independent privacy statements, notices, and terms. We cannot control or be
held responsible for third parties’ privacy practices and content. Please read their privacy policies
carefully to find out how they collect and process your Personal Information prior to submitting
any Personal Information via those third-party websites. The collection, use, and disclosure of your
Personal Information will be subject to the privacy policies of the third party and not this Policy.
We are not responsible for the data collection, privacy, and information sharing policies and
procedures or content of such third-party websites.

12. Changes to this Policy

All changes to this Policy are effective when they are posted on this webpage. Your continued
relationship with us after the posting of any amended version of this Policy shall constitute your
agreement to be bound by any such changes.

If we change this Policy in a material manner, we will let you know via email and/or by posting a
prominent notice on our website prior to the change becoming effective and by updating the
“Effective Date” at the top of this page.

We encourage you to review this Policy periodically to remain informed of how we use and protect
your Personal Information, and to be aware of any Policy changes.

13. Questions or Comments

If you have any questions or comments regarding this Policy, please contact us at:

Kirby Stock Exchange LLC
P.O. Box 468
Rutherford, NJ 07070

We will address your concerns and attempt to resolve any privacy issues in a timely manner and
in accordance with all applicable laws.