Privacy Policy

Last updated: April 22, 2026

1. Introduction

Deep MM, Inc. ("the Company," "we," "us," or "our") operates deepmarketmaking.org and the Deep MM bond pricing terminal (the "Service"). This Privacy Policy explains what personal information we collect, how we use it, and the rights available to you. It applies to information collected through the Service and through direct communications with us.

Deep MM provides AI-generated option-adjusted spread (OAS) fair value signals for institutional fixed-income desks trading investment-grade, high-yield, and emerging-market corporate bonds. The market data we process to generate pricing signals consists of publicly available FINRA TRACE trade prints, dealer-provided axis inventory submissions, and cross-asset market inputs such as CDS spreads and swap rates. These inputs are market data, not personal information, and are not covered by this Policy. This Policy covers personal information of individuals who register for, access, or contact the Service.

The Company is based at 48 Wall Street, 11th Floor, New York, NY 10005 and can be reached at [email protected].

2. Information We Collect

2.1 Information You Provide

When you request terminal access, register for a desk account, contact us by form or email, or respond to an onboarding inquiry, we collect:

• Full name and job title;
• Employer organization name and desk type (for example, IG credit, HY trading, portfolio management);
• Business email address and, where provided, phone number;
• The content of any messages or support inquiries you send us.

2.2 Information Collected Automatically

When you visit deepmarketmaking.org or use the web terminal, we automatically collect limited technical information:

• IP address and approximate location (city/region level);
• Browser type, operating system, device class;
• Pages and terminal features accessed, referring URLs, session duration;
• Cookie and similar identifiers (see Section 5 and our Cookie Policy).

We do not collect or retain the specific bond pricing queries you submit through the terminal beyond what is necessary to deliver the pricing response and maintain API usage logs for service reliability.

2.3 We Do Not Knowingly Collect Children's Data

The Service is directed exclusively to professionals at institutional trading desks and is not intended for individuals under 18. We do not knowingly collect personal information from children under 13. If you believe a child has provided information, contact [email protected] and we will delete it.

3. How We Use Information

We use the information we collect to:

• Verify institutional desk eligibility and provision access to the terminal and API;
• Respond to inquiries, schedule onboarding sessions, and provide technical support;
• Operate, monitor, and improve the Service and the underlying pricing signal infrastructure;
• Send service updates, API maintenance notices, and (with your consent where required) research publications or product announcements;
• Detect, investigate, and prevent unauthorized access or abuse of the API or terminal;
• Comply with applicable legal obligations, including any recordkeeping requirements that arise in connection with services provided to registered broker-dealer or investment adviser clients.

We do not sell personal information for monetary value. Where applicable state law treats certain advertising arrangements as a "sale" or "share," see Section 9 below.

4. Sharing of Information

We share personal information only with:

• Service providers acting on our behalf (including cloud hosting, email delivery, and platform analytics) under contractual confidentiality and data-processing terms;
• Regulatory or governmental authorities when required by law or court order, or to protect the rights, safety, or property of the Company or others;
• A successor entity in the event of a merger, acquisition, or asset sale, subject to the same protections described in this Policy.

We do not sell personal information to third parties.

Note regarding institutional subscribers: Organizations that subscribe to the Deep MM platform agree separately to our data processing terms. Individuals who access the Service through their employer's subscription should also consult their employer's own privacy policies.

5. Cookies and Tracking

We use cookies and similar technologies to maintain your terminal session, remember preferences, and measure aggregate platform usage. For details and your choices, see our Cookie Policy.

6. Data Retention

We retain account registration and contact information for as long as an account is active and for a reasonable period thereafter to support service continuity, respond to inquiries, and fulfill legal or contractual obligations. Inactive accounts not renewed after subscription expiry are scheduled for deletion after 24 months. Server access logs and API request logs are retained for 90 days and then aggregated into anonymized usage statistics. Support and onboarding correspondence may be retained for up to three years.

7. Security

We apply administrative, technical, and physical safeguards appropriate to a financial-sector data service, including TLS encryption in transit, restricted-access cloud infrastructure with least-privilege access controls, and access logging for terminal and API systems. Our institutional subscribers remain independently responsible for their own firm-level data security and regulatory obligations, including SEC Regulation S-P where applicable. No system is perfectly secure; we cannot guarantee absolute security against all threats.

8. Your General Rights

Depending on your jurisdiction, you may have rights including access, correction, deletion, and the ability to limit certain processing of your personal information. To make a request, email [email protected]. We will respond within the timeframe required by applicable law.

9. New York Residents

New York does not currently have a comprehensive consumer privacy statute. As a matter of policy, we extend the following baseline rights to all U.S. residents regardless of state of residence.

9.1 Baseline Rights

• Right to Know: request the categories of personal information we have collected about you.
• Right to Delete: request deletion of personal information you have provided.
• Right to Correct: request correction of inaccurate personal information.
• Right to Opt Out of Marketing: unsubscribe from marketing emails or opt out via the link in each marketing message.

9.2 How to Exercise

Email [email protected] with a description of your request and enough detail for us to verify your identity. We respond within 45 days.

9.3 Sector-Specific Rights

If you are protected by federal sector laws (for example, GLBA or SEC Regulation S-P), those laws may give you additional rights with respect to financial information covered by them.

9.4 California Visitors

If you are a California resident, you may also exercise the rights granted under the California Consumer Privacy Act ("CCPA") and California Privacy Rights Act ("CPRA"), including the right to know, the right to delete, the right to correct, and the right to opt out of sale or sharing. We do not sell personal information and do not "share" personal information for cross-context behavioral advertising.

To submit a CCPA / CPRA request, email [email protected] with the subject line "California Privacy Request."

10. Changes to This Policy

We may update this Policy from time to time. Material changes will be reflected by a new "Last updated" date and, where appropriate, a notice posted on the Service.

11. Contact

Deep MM, Inc.
48 Wall Street, 11th Floor
New York, NY 10005
Email: [email protected]
Phone: +1 (212) 730-0148