Policy Effective Date: April 14, 2025

Your Privacy Matters

At Moment, maintaining your trust is paramount. We understand that protecting your privacy is indispensable to both earning and upholding that trust. This guiding principle informs every decision we make, as well as how we collect, utilize, and store any information you provide to us.

We created this Privacy Policy to be as clear and direct as possible about how we gather and use your non-public personal information and other types of personal information (“Personal Information”) and to assist you in exercising your privacy rights.

Introduction

Moment Technology and/or its affiliates (“Moment”, “we”, “us” and/or “our”) currently offer a  technology based service to enable market participants to interact with liquidity providers for the purpose of purchasing and selling fixed income investments, and may offer additional products and services in the future (collectively, the “Services”), through Moment’s website, www.withmoment.com (“Site”) and our API based Web App (“App”). This Privacy Policy describes how Moment treats your Personal Information when you or your agent uses our Site, Web App and/or Services. This Privacy Policy is jointly issued by Moment Technology, Moment Advisors LLC, and Moment Markets LLC. Each entity is committed to upholding the privacy practices outlined herein, ensuring the protection and responsible handling of your Personal Information across all our services.

For the purpose of this Privacy Policy, a “User” is a party that accesses and interacts with our website.  An “Agent” is a financial intermediary who transacts or makes investment decisions on your behalf; and a “Client” is a party who signs a  Client Agreement with an Agent.

If you visit our website, we may collect information about the way you are accessing our site.  Moreover, if your Agent uses Moment Services, it may provide certain personal data to Moment.  Such data is provided for the purpose of enabling your Agent to select investments on your behalf and to facilitate the clearance and settlement of such transactions.  For example, your Agent could tell us to provide municipal bonds of a certain characteristic, including your geographical location.  Similarly, your agent could provide your financial account number and name to facilitate the allocation of investments into your account.

Information Collection

The categories of information we collect from Users differs from what we collect from those who qualify as Clients. For example, if you visit our website, we may collect the following information:

Automatic Data Collection. When you use our Services, we may collect your Internet protocol (“IP”) address; cookie identifiers; mobile carrier, mobile advertising and other unique identifiers; details about your browser, operating system or device; location information; Internet service provider information; pages that you visit before, during and after using the Services; information about the links you click; and other information about how you use the Services. Information we collect may be associated with accounts and other devices.

Anonymized or Aggregated Information. Moment’s Site and App record certain anonymized or aggregated information about your use or evaluation of our Services. Anonymized or aggregated information is used for a variety of purposes, including the measurement of Users’ and Clients’ interest in and use of various portions or features of the Site and App. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including for internal analysis and research. We may share this information with third parties for our purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.

Cookies and Pixels. Similar to other consumer internet services, Moment uses cookies, a small piece of computer code that enables our Web servers to identify Users and Clients, each time an individual initiates a session on our Site. A cookie is set in order to identify you and tailor the Site to you. Cookies do not store any of the Personal Information that you provided to us; they are simply identifiers. You may delete cookie files from your hard drive at any time through your browser settings. However, cookies may be necessary to provide access to much of the content and many of the features of the Site.

Pixel Tags. Along with cookies, we may use “pixel tags,” also known as “web beacons,” which are small graphic files that allow us to monitor the use of our Site. A pixel tag can collect information such as the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the type of browser that fetched the pixel tag; and the identification number of any cookie on the computer previously placed by that server.

Site and App Activity. Moment may also use third-party tracking technology, such as Google Analytics, to record your activity on our Site and App.

“Do Not Track” Technology. We do not collect Personal Information about your online activities over time and across different websites or online services. Therefore, our Site does not respond to Do Not Track (“DNT”) signals. We do not knowingly authorize third parties to collect Personal Information about your online activities over time and across different websites or online services.

Information We Collect About Clients

We collect Personal Information about Clients when an Agent, directly or through its clearing broker provides it to us for the purpose of facilitating trading activity, such as following booking instructions, or settlement of transactions. 

We generally do not have direct contact with Clients. Moment, therefore does not receive direct Client consent for the use and processing of their Personal Information. To the extent Personal information about you is provided to us by an Agent, we assume, based on our contractual relationship that they have lawfully received your consent to use your Personal Information in the manner and for the purpose for which it is conveyed to us.  

The Personal Information provided in this context may include but may not be limited to: name, e-mail address, telephone number, zip code, birth date; investable assets, income information, and other financial planning information about your household; as well as account numbers and routing numbers for the financial accounts you choose to settle transactions and custody investments. 

Moment may use a limited amount of the Personal Information provided by your Agent. We will only use the information that is necessary to complete the specific instructions provided by your Agent. Any Personal Information that is provided to us is preserved in our servers in the context of booking or settlement instructions provided by your Agent.

Clients may request deletion of Personal Information held by Moment in accordance with the “Retention and Deletion” section below. Moment does not share your Personal Information with outside parties except in limited cases relating to fraud investigations. In such fraud investigations, we may share certain of your Personal Information with your Agent or its clearing or custody institution. We also reserve the right to share your Personal Information with third parties as required by law.

How we use Information

No Renting, Selling or Trading Out List
We will never rent, sell, or trade your Personal Information to anyone. 

User Personal Information
We utilize the Personal Information of our Users for a variety of business purposes, such as to help our Users evaluate our Services, offer new products and services, enhance our Services, and for research and internal analysis.

Client Personal Information
Moment stores, processes, and maintains Personal Information about Clients for a variety of business reasons such as enabling your Agent to have the necessary information to select investments on your behalf and to facilitate the booking and settlement of such transactions.  In addition we may use your Personal Information for the purposes of evaluating the offering of new products and services as well as enhancing our existing services. In addition, we may use your information for research and internal analysis. 

Social Media and Links to Other Websites and Applications
This Privacy Policy and these terms apply only to Moment-operated Services and applications. Please note as a User that our Site and Apps may for your convenience contain links to other websites, applications and information that are not operated by Moment. Moment does not control these linked third-party websites or their privacy practices, which may differ from those set out in this Privacy Policy. Any Personal Information you choose to provide to linked third parties is not covered by this Privacy Policy. We encourage you to review the privacy policy of each company or website before submitting any Personal Information. Some third parties may choose to share their users’ Personal Information with us; that sharing is governed by that company’s privacy policy, not this Privacy Policy.

Information Sharing and Onward Transfer

We will not share or disclose your Personal Information (whether you are a current or former User or Client) with any unaffiliated third parties except:

To Protect Ourselves or Others. We may share your Personal Information as required by law, such as when we reasonably believe it is necessary or appropriate to investigate, prevent, or take action regarding illegal activities or suspected fraud if we believe doing so is required or appropriate to: comply with law enforcement or national security requests and legal process, such as a court order or subpoena; to protect your, our or others’ rights, property, or safety; enforce our policies or contracts; or collect amounts owed to us.

Affiliates. Moment may share your Personal Information among affiliated Moment entities in connection with the provision of Services to Clients and Users.

Service Providers. There are certain circumstances in which we may share your Personal Information with unaffiliated third-party service providers, including to perform certain business and technology-related functions and to support the provision of the Services. We may share your Personal Information with unaffiliated third-party service providers for the provision of certain services, including but not limited to the following: trade settlement and clearing; data processing and storage; payment processing; identification verification and fraud detection; customer support; and marketing. These service providers are required to protect your information and use it only for the purposes for which it was disclosed. We do not share Personal Information with any third parties for their own marketing purposes.

Disclosure in the Event of Merger, Sale, or Other Asset Transfers. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your Personal Information may be transferred as part of such a transaction, as permitted by law and/or contract.

Your Choices and Opting Out

General
You have choices regarding the use and disclosure of your Personal Information, as set out in this Privacy Policy.

You may decline to provide Personal Information to your Agent or otherwise modify or withdraw the consent you gave your Agent to use Moment in connection with the purpose for which we use your Personal Information. Revoking or modifying your consent, however, could prevent us from processing your transactions in accordance with your Agent’s instructions.

Opting Out - Obtaining and Withdrawing Consent
Where you have consented to Moment’s ability to process use of your Personal Information, you may withdraw that consent at any time by contacting your Agent in the manner prescribed in your Agent’s Privacy Policy.  

You also can contact us directly by email or physical mail via the contacts indicated under the “Questions and Contacting Us” section below. Clients and Users cannot opt out of providing Personal Information to Moment and continue to benefit from the services provided by Moment. Even if you opt out, we may still collect and use non-personal information regarding your activities for other legal and regulatory purposes as described above. 

Accessing Your Personal Information
Users or Clients may contact us at compliance@withmoment.com to request information about how to access your Personal Information.

Your requests will be processed consistent with existing laws, including without undue delay and in accordance with any required time frames. Although Moment makes good faith efforts to provide individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information is protected from disclosure by certain privileges and protections, where doing so would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will endeavor to provide you with an explanation of why that determination has been made within one month of the request, a contact point for any further inquiries, and any other legally-required information. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access or making any changes to your Personal Information.

Retention and Deletion
Moment retains the Personal Information we receive as described in this Privacy Policy for as long as you use our Site or as necessary to fulfill the purpose(s) for which it was collected, to provide our services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, or as otherwise required to comply with contracts and comply with all applicable laws.

Due to regulatory record-keeping obligations, we may retain information related to you and your account, as well as any data related to your trades, in accordance with applicable laws. In no case will we share any individual trading data unless required by your Agent, regulators or other government bodies, to support processing of settlement of your transactions, or in accordance with applicable laws.

User Deletion Requests. If you are a User (as defined in the Introduction of this Privacy Policy) you may request deletion of Personal Information by contacting compliance@withmoment.com.

Client Deletion Requests. In connection with separate regulatory record-keeping obligations imposed on our regulated affiliates, we may be required to maintain and not delete Personal Information associated with Clients.

Other Important Information

Security
Moment takes reasonable steps, endeavoring to use appropriate technical or organizational measures, to protect your Personal Information from loss, misuse, unauthorized access, alteration, disclosure, or destruction. However, no Internet, email, or electronic operating system that enables the transmission of data is ever fully secure or error-free; therefore, we cannot ensure or warrant the security of any information you transmit to us.

Federal Privacy Laws
Please be aware that certain federal privacy laws govern the collection and record keeping of nonpublic Personal Information collected by regulated entities of Moment, and state privacy laws may be inapplicable in certain situations related to such Personal Information.

Notice to California Residents
To the extent not covered by the federal privacy regulations noted above, California residents may have the following rights with respect to data collected by Moment.

California law permits Users and Clients who are residents of California to request and obtain from us once a year, free of charge, a list of the third-parties to whom we have disclosed their Personal Information (if any) for those third-parties’ direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Please note that this disclosure requirement only applies if we share Personal Information with third parties for those third parties to directly market their own products to those consumers, and Moment does not share Personal Information with third parties for those third parties to directly market their own products to Users or Clients.

Under the California Consumer Privacy Act (CCPA) Users who are California residents may request and obtain from us twice a year, free of charge, information related to Personal Information we have collected in the 12 months preceding the request.

Changes to this Privacy Policy

We may update this Privacy Policy from time to time as we deem necessary at our sole discretion. If there are material changes to this Privacy Policy, we will notify you as required by applicable law.

This document constitutes Moment’s complete Privacy Policy for Moment and its affiliates and the services and website.

Questions and Contacting Us

If after reviewing this Privacy Policy, you would like to submit a request to exercise your rights as detailed in this Privacy Policy or have any questions or privacy concerns, please contact us by email at compliance@withmoment.com or via physical mail at:

Moment Technology, Inc.
101 Greenwich Street, Floor 9
New York, NY 10006