Terms and Conditions

SIFMA Foundation Privacy Policy

SIFMA Foundation has created this statement so that you understand our information gathering and  
dissemination practices both on and off the website.

SIFMA Foundation is an educational, charitable 501(c)(3) organization that is dedicated to advancing  
financial readiness for elementary, middle, and high school students in schools and other youth-serving  
nonprofits nationwide. Launched in 1977, SIFMA Foundation offers programs and tools such as The  
Stock Market GameTMthat equip educators to advance their students’ financial capability. To date, our  
programs have enabled 22 million students to prepare effectively for their financial futures, improve their  
academic and life skills, and gain exposure to opportunities for college and careers.

Children

To respect the privacy of minors, SIFMA Foundation does not knowingly collect, maintain,  
or process Personal Information submitted online via our Internet Services by anyone  
under the age of 18.

What Personal Information We Collect

SIFMA Foundation’s Stock Market Game website (www.stockmarketgame.org) is a non-commercial,  
educational website. It is designed to enable educators to access curricula and enriching educational  
simulations for their students and is meant solely for the purpose of reinforcing positive outcomes for  
youth development.

The website does not collect any personal information about you (the user) unless you specifically and  
knowingly provide such information when you register for or participate in our programs. In this case, we  
request basic contact information (such as name, e-mail address, phone, and school address) for the  
purpose of providing you access to the password protected curricula and student simulations, and we  
request the grade levels, school type, and subject area that are of interest to you.

We retain varying amounts of the information you provide us only for as long as necessary for our  
legitimate interests in pursuing the educational support purposes outlined in this Privacy Policy.

When We Collect It

Submitting personal information is not required to use the SIFMA Foundation website except to access  
password-protected portions of the educational website. We only collect information from you, as stated  
above, when you knowingly and voluntarily provide this information in registering for SIFMA  
Foundation’s educational programs.

What We Do With It

We use your information to generate customized teacher and student accounts and their accompanying  
passwords so that you may safely and accurately access teaching materials, rubrics and lesson plans and  
your students may access the interactive educational online activities that support The Stock Market  
Game investment simulation.

For United States residents, we will send you information specific to your program participation, but you  
can opt-out of any electronic mailings. We maintain compliance with marketing requirements outlined in  
the CAN-SPAM Act, the Telephone Consumer Protection Act, and other applicable law.

For European Union and Canadian residents, we undertake marketing only with your expressive  
affirmative consent and in compliance with applicable data privacy laws. EU and Canadian residents are  
added to the marketing lists only when they provide express affirmative consent consistent with  
applicable data protection laws, so be sure to let us know what information is most useful.

Disclosure and Transfer of Personal Information

We may on rare occasion disclose limited personal information you provide via registration to outside  
companies that help us bring you the noncommercial, educational services we offer. For example, we may  
work with an outside company to: (a) manage our databases; (b) assist us in distributing our program related  
emails;(c) assist us with direct marketing and data collection; (d) provide us storage and analysis; (d) provide  
fraud prevention;and (e) provide other services designed to assist us in maximizing our program reach and  
positive educational impact.We require that these outside companies agree to keep confidential all information  
we share with them and to usethe information only to perform their obligations in our agreements with them.

We may disclose information to comply with applicable laws and regulations, such as to respond to a  
subpoena or similar legal process, to protect against misuse or unauthorized use of our website, to limit  
our legal liability, and to protect our rights or to protect the rights, property, or safety of visitors of this  
website or the public, and to otherwise cooperate with law enforcement or regulatory authorities.  
We may transfer or share a copy of your registration information in the event that SIFMA Foundation or  
one of its properties goes through a business transition, such as a merger or being acquired by another  
organization. You will be notified via email or prominent notice on our website prior to a change of  
ownership or control of your personal information, if your personal information will be used contrary to  
this policy.

Nothing in this Privacy Policy is intended to interfere with the ability of SIFMA Foundation to transfer all  
or part of its activities or assets to an affiliate or independent third party at any time, for any purpose,  
without any limitation. SIFMA Foundation specifically reserves the right to transfer or share, as needed,  
with that third party a copy of personally identifiable information collected from its websites.

Cookies and Other Tracking Technologies

SIFMA Foundation uses Google Analytics; you may turn off Google Analytics tracking and disable  
cookies in your browser settings. Google Analytics does not share actual IP address information with  
Google Analytics customers. In addition, SIFMA Foundation’s instance of Google Analytics does not  
have Signal enabled and all remarketing and advertising features have been disabled.

We may also track users by IP address and by Cookies (cookies can be disabled in your browser settings)  
for broad demographic data, as well as to help make sure that we are delivering the information you want.

“Do Not Track” signals are options available on your browser to tell operators of websites that you do not  
wish to have your online activity tracked. Our websites operate no differently if these “Do Not Track”  
signals are enabled or disabled. Our Internet Services do not allow any third parties to collect Personal  
Information about your online activities over time or across websites for their own purposes.

California Privacy Rights

Under California Civil Code Section 1798.83, California customers are entitled to request information  
relating to whether a business has disclosed personal information to any third parties for the third parties’  
direct marketing purposes. That notice will identify the categories of information shared and will include  
a list of the third parties and affiliates with which it was shared, along with their names and addresses. If  
you are a California resident and would like to make such a request, please submit your request in writing  
at the address information below.

EU Data Storage, Access, The Right to be Forgotten, and Dispute Resolution

We store personal data for different periods of time consistent with the purposes for which they were  
originally collected, as subsequently further authorized, or when required or allowed under applicable  
law.

Individuals in Europe have certain data subject rights which may be subject to limitations and/or  
restrictions. These rights may include the right to: (i) request access to and rectification or erasure of their  
personal data; (ii) obtain restriction of processing or to object to processing of their personal data; and (iii)  
the right to data portability. If you wish to exercise one of the above mentioned rights, please send us your  
request via email to: [email protected]. Individuals in Europe may also have the right to lodge a complaint  
about the processing of their personal data with their local data protection authority.

In addition to the rights above, SIFMA Foundation is committed to providing all individuals with access  
to their personal data. If you believe that SIFMA Foundation may be processing data about you and wish  
to have access to that information, we can provide you with that data or at least an explanation of why we  
cannot do so in the particular context, such as if responding to the request would be unreasonably  
expensive. Please also let us know if you have any questions, concerns, disputes, or issues. We are  
always open to dialogue to resolve issues. If your concerns cannot be resolved, we can enter into  
appropriate third-party neutral dispute resolution. If you need to reach us about a privacy or data  
protection issue, please contact us at the information below.

How to contact us about privacy

If you have any questions about our privacy policy, the information we have collected from you online,  
the practices of this site or your interaction with this website, please send email to: [email protected] or call  
212.313.1000 or write us at 140 Broadway, 35thFloor, New York, NY 10005.