Privacy Policy

Markley, LLC Privacy Policy

Last Updated: October 20th, 2020

1. Overview

Thank you for visiting Markley’s website and reviewing this Website Privacy Policy. Our Website Privacy Policy explains how we handle the information you provide to us when you visit us online.

This policy informs you of our practices regarding the collection, use, and disclosure of personal data when you use our website and the choices you have associated with that data.  We use your data to provide and improve the website. By using the website, you agree to the collection and use of information in accordance with this policy. This policy also describes your choices regarding access to, and use and correction of, personal information that Markley maintains about you.

2.  Privacy Policy Contact Information

Markley understands and respects an individual’s right to be informed, right of access, right to rectification, right to erasure, right to restrict process, right to data portability, right to object, and rights in relation to automated decision making and profiling. An individual always has the right to object to processing for the purposes of direct marketing, whatever lawful basis applies. An individual also has the right to erase personal data which has been processed unlawfully. An individual has the right to be informed of how their personal data is being used throughout Markley. Therefore, Markley will provide people with information about Markley’s lawful basis for processing in the form of a privacy notice.

Individuals can contact our Chief Privacy Officer and Compliance Department by emailing privacy@markleygroup.com and/or calling (617) 451-6464 with any questions, comments, or requests about their personal data.

Markley Group, Compliance Department

One Summer Street, Fifth Floor

Boston, MA, 02100

If you believe you have suffered harm due to a breach of your rights by Markley under this privacy policy, and Markley has not handled your complaint in a reasonably sufficient manner, any EU resident may also file a complaint with the applicable supervisory authority. The EU Commission has a list of data protection authorities here: https://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.

3.  Privacy Policy Changes

We may update this policy from time to time. We will notify you of any changes by posting the new policy on this page.  You are advised to review this policy periodically for any changes. Changes to this policy are effective when they are posted on this page.

4. What We Collect

The security of your data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee its absolute security.

We collect personal identifiable information, usage data, and tracking & cookie data.

Personal Identifiable Information (PII): When you visit our Site or email us, we collect information sent to us by your computer, mobile phone, or other access device—some of which may be deemed Personal Information. The information sent to us may include but is not limited to the following: information about the pages you access, computer IP address, device ID or unique identifier, device type, geo-location information, computer and connection information, mobile network information, statistics on page views, traffic to and from the sites, referral URL, ad information, and standard web log Information and other information. We may also collect anonymous information through our use of cookies and web beacons.

You may provide PII to us when you send us an e-mail message or request information, fill out a form or survey, or submit contact information on our site. We do not require you to register or provide PII to visit our website. We do collect some technical information that does not include PII when you visit to make your visit seamless. The information below explains how we handle and collect information when you visit our site.

Usage Data: When using our website, we collect information about how the Site is accessed and used ("Usage Data"). This Usage Data may include information such as your computer's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Site that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

Tracking & Cookie Data: We use cookies to track the activity on our Site and hold certain information. Cookies are files with a small amount of data which may include an anonymous unique identifier. Cookies are sent to your browser from our website and stored on your device. These cookies are used to collect information about how you interact with our website and allow us to remember you. We use this information to improve and customize your browsing experience and for analytics and metrics about our visitors both on this website and other media. Tracking technologies may also include beacons, tags, and scripts to collect and track information and to improve and analyze the Site. 

Examples of Cookies we use:

  • Strictly Necessary Cookies. These cookies are necessary for the website to function and cannot be switched off in our systems. They are usually only set in response to actions made by you which amount to a request for services, such as setting your privacy preferences, logging in or filling in forms. You can set your browser to block or alert you about these cookies, but some parts of the site will not then work. These cookies do not store any personally identifiable information.
  • Functional Cookies. These cookies enable the website to provide enhanced functionality and personalization. They may be set by us or by third party providers whose services we have added to our pages. If you do not allow these cookies then some or all of these services may not function properly.
  • Performance Cookies. These cookies allow us to count visits and traffic sources so we can measure and improve the performance of our site. They help us to know which pages are the most and least popular and see how visitors move around the site. All information these cookies collect is aggregated and therefore anonymous. If you do not allow these cookies we will not know when you have visited our site, and will not be able to monitor its performance.
  • Targeting Cookies. These cookies may be set through our site by our advertising partners. They may be used by those companies to build a profile of your interests and show you relevant adverts on other sites. They do not store directly personal information, but are based on uniquely identifying your browser and internet device. If you do not allow these cookies, you will experience less targeted advertising.

Independent of the Site, you can instruct your browser to refuse all cookies or to indicate when a cookie is being sent.

Upon navigating to the Site, a banner is displayed allowing you to agree to or decline the use of cookies by the Site. By selecting “Agree”, continuing to browse, or closing this banner, you agree to the use of cookies that our website stores on your computer. By declining, your information won’t be tracked. A single cookie will be stored to remember your preference. If you do not agree to the use of cookies, you may not be able to use some portions of our Site.

To change your settings, click here:

A preference center window will pop up, allowing you to edit your choices.

5.  How We Use Your Data

Markley may use your information for any purpose not inconsistent with our statements in this policy or prohibited by applicable law, including to:

  • Provide and maintain the Site
  • Notify you about changes to our Site
  • Allow you to participate in interactive features of our Site when you choose to do so
  • Provide customer care and support
  • Provide analysis or valuable information so that we can improve the Site
  • Monitor the usage of the Site
  • Detect, prevent and address technical issues
  • Promote the use of our Site and distribute informational and promotional content, according to your communication preferences

5.1.1 Transfer of Data

Your personal data may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.  If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there.  Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.  Markley will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy.  No transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

5.1.2 Disclosure of Data

We may employ third party companies and individuals to facilitate our Site ("Service Providers"), to provide the Site on our behalf, to perform Site-related services or to assist us in analyzing how our Site is used.  These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose. These service providers are prohibited from using your PII for any purpose other than to provide necessary assistance, although we may permit them to use aggregate information for other purposes. We may also share information about you with our service providers as follows to:

  • Comply with a legal obligation
  • Protect and defend the rights or property of Markley
  • Prevent or investigate possible wrongdoing in connection with the Site
  • Protect the personal safety of users of the Site or the public
  • Protect against legal liability

6.  Third-Party Website and Applications

We will not disclose your personal data to third parties except as follows:

  • When we believe release is appropriate to comply with the law, such as in response to lawful requests by public authorities to meet national security or law enforcement requirements.
  • To enforce our services agreement and other rights, or to protect the rights and safety of others. This may include exchanging information with government regulatory or law enforcement agencies, or with other companies and organizations for fraud protection and legal compliance.
  • To persons who help us provide our products and services to you. We may provide personal and other information to third parties who work for us, such as companies that verify/analyze data, manage contact information and communications, remove repetitive information from customer lists, and provide marketing services. These providers are not authorized to further disclose your data or to use your data for any other purpose other than providing services to us.
  • Our site is hosted by a third party and we use third party infrastructure monitoring services. These third parties may have inadvertent or incidental access to your data.  These providers are not authorized to further disclose your data or to use your data for any purpose other than providing services to us.

We may disclose data we collect from and about you in aggregate anonymous form for the purpose of improving our site and services generally.  This may include combining data about you (in anonymous form) with data we have about other individuals (in anonymous form), and transferring the combined data to third parties.

This web site may contain links to non-affiliated websites. Your use of any third party site, including the submission of personal information, will be governed by the terms and conditions of the site operator. Markley is not responsible for the practices or content of any third-party site, even if we provide a link from our website.

7.  Interaction With Children Online

Our Site does not target and is not intended to attract children or minors under the age of 16. Markley does not knowingly solicit personal information from children or minors under the age of 16 or send them requests for personal information. If you believe we have collected personal information from a person under 16 years old without the consent of their parent or legal guardian, please let us know immediately by contacting us as indicated in this Policy and providing sufficient information so we can act appropriately.

8.  Visiting Other Websites

The Site may contain hyperlinks to other web sites operated by parties other than Markley. Such hyperlinks are provided for your convenience only and you access them at your own risk. Any other web site accessed from this Site is independent from Markley, and Markley has no control over and is not responsible for the content, privacy policies, or practices of that other web site. In addition, a link to any other web site does not imply that Markley endorses or accepts any responsibility for the content, availability or use of that web site, or of any product or service provided by a third party.