Effective Data: June 9, 2023

Marco Polo Exchange (“MPX”) is committed to respecting the privacy rights of its users. This privacy policy (“Privacy Policy”) applies to Marco Polo Exchange’s, and its related companies’ and subsidiaries’ (“We” or “MPX”) online websites and platforms, including the www.mpxchange.com and other MPX websites (collectively, the “Services”).


In using the Service, you may be requested to provide certain information such as your name, address (postal and email) and telephone number. This information may be stored in our database.

Except as otherwise provided in this Privacy Policy, we do not sell or license personally identifiable information to third parties. We may use personally identifiable information to administer and improve the Service, customer support, to send you information about MPX or the Service, to contact you when necessary and for such other purposes as you may consent. We also share personal information with our business partners who assist us by performing certain services (such as hosting, billing, fulfillment or data storage and security) related to the Service. Those business partners have all agreed to uphold similar standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use such information to carry out their specific business obligations to MPX.


We use “cookies” to collect information and to provide you with a better service. We may customize content specific to your interests, store your password so you do not have to re-enter it each time you use the Service, and promote the Service to you. You can instruct your computer to not accept cookies; however, if you do so, you may not be able to use all aspects of the Service.


We follow generally accepted industry standards to protect personal information submitted to us. MPX uses reasonable measures to safeguard personally identifiable information, which measures are appropriate to the type of information maintained, and follows applicable laws regarding safeguarding any such information under our control. MPX uses certain trusted third party companies to provide and improve the Service, including data storage and hosting operations. These third parties may have access to your information only for the purposes of performing tasks on our behalf and under obligations similar to those in this Privacy Policy. While we believe that we have taken reasonable steps to secure data collected from our customers, no security system is impenetrable.

Each User is responsible for protecting the confidentiality of, but not limited to, their username, password and other authenticating information and processes from third party access associated with the User’s account, and for selecting passwords that are secure. Each User must promptly notify us within one calendar day if their username or password is lost, stolen, or used without permission so that appropriate action can be taken to modify User’s account. In such an event, we will remove that username or password from your account and update our records accordingly. The Service may contain links to third party websites. We are not responsible for the privacy practices or the content of such websites.


Except as otherwise provided in this Privacy Policy, we will use commercially reasonable efforts to protect and safeguard all personal information against unauthorized use, publication or disclosure, and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms of Service, take precautions against liability, to investigate and defend ourselves against third-party claims or allegations, to assist government enforcement agencies in connection with an investigation or to protect the security or integrity of the Service. Information that you store or exchange on the Service will immediately become available to those whom you have authorized to view such information, and MPX is not responsible for the privacy or disclosure practices of such recipients. We restrict access by our personnel to such information except as necessary to maintain and provide the Service or if the customer requests our assistance. If MPX is involved in a business divestiture, change of control, sale, merger or acquisition of all or a part of its business, we reserve the right to transfer your information.


We collect a variety of information via the use of the Service and at the direction of customers, and may not have a direct relationship to the individual whose personal data those customers process. As an individual, if you have concerns about your personal information being processed or if you seek access or want to correct, amend or delete inaccurate data, please email MPX at clientservices@mpxchange.com and we will work with you and the organization responsible for processing your personal data to respond to your request within a reasonable timeframe.


In certain situations, MPX may be required to disclose personal data in response to lawful requests by public or governmental authorities, including to meet national security or law enforcement requirements.


If you believe MPX processes your personal data and have inquiries and concerns that you would like to discuss with us, please contact MPX at clientservices@MPXchange.com.


MPX engages third-party service providers to assist in providing the Service, including for management of some aspects of the Services and related support functionality.


We will share your personal information with third parties only in the ways that are described in this privacy statement. From time to time, we may disclose your personally identifiable information to certain third party vendors used by MPX to assist us in providing the Service, to the extent necessary to enable such vendors to provide such assistance. These third parties are prohibited from using your personally identifiable information for any other purposes. If you do not want us to share your personal information with these vendors, email us directly at clientservices@mpxchange.com. Such restrictions may limit our ability to continue to provide you with some or all of the Services.


You may update or correct your personal information and email preferences at any time by emailing us directly at clientservices@mpxchange.com.


If we change this Privacy Policy, we will post those changes on this page. Such changes are effective when posted on this page. By continuing to use the Service after the changes are made, you agree to be bound by the updated Privacy Policy. If you have any questions about this Privacy Policy, please contact us at clientservices@mpxchange.com.


This section applies only to California residents. We adopt this notice to comply with the California Consumer Privacy Act (“CCPA”) and other California privacy laws, as amended. For purposes of this section, any terms defined in the CCPA have the same meaning when used in this notice.

MPX does not sell (as such term is defined in the CCPA) the Personal Information we collect, and will not sell it without providing a right to opt out.

Your California privacy rights. You have the following rights under the CCPA:

  • Information. To request the following information about how we have collected and used your Personal Information during the past 12 months:
  • The categories of Personal Information that we have collected.
  • The categories of sources from which we collected Personal Information.
  • The business or commercial purpose for collecting Personal Information.
  • The categories of third parties with whom we share Personal Information.
  • Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information disclosed to each category of third party recipient.
  • Access. To request a copy of the Personal Information that we have collected about you during the past 12 months.
    Deletion. To request that we delete the Personal Information that we have collected from you.
  • Nondiscrimination. To exercise the rights described above free from discrimination as provided in the CCPA.

How to Make Requests

If you are a California resident, you can make a Request to Know, Delete, or Correct by submitting your request via email to clientservices@mpxchange.com; or the form located here.

When you make a Request to Know, Delete, or Correct, we will attempt to verify that you are who you say you are. For example, we will attempt to match information that you provide in making your Request with other sources of similar information to reasonably verify identity.

We will need to verify your identity to process your information, access and deletion requests and we reserve the right to confirm your California residency. You may be required to provide government identification, give a declaration as to your identity under penalty of perjury and/or provide additional information. If you wish to designate an authorized agent to make a request on your behalf, we will need to verify both your and your agent’s identities and your agent must provide a valid power of attorney pursuant to California Probate Code Sections 4000-4465. If you have not provided your agent with such a power of attorney, you must provide your agent signed permission to exercise your CCPA rights on your behalf, provide the information we request to verify your identity, and provide us with written confirmation that you have given the authorized agent permission to submit the request. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. In certain cases, we may be required or permitted by law to deny your request.