Effective Date: November 16, 2023
Last Updated: [November 1, 2025]
Derivative Path, Inc., including its subsidiaries and affiliates (collectively, “Derivative Path”, “we”, “us”, or “our”) respects your privacy. This Privacy Policy describes how we collect, use, disclose and protect personal information in connection with our websites, products and services (collectively, the “Services”). Please read this Privacy Policy carefully to understand our policies and practices.
By accessing or using our Services, you agree to the terms of this Privacy Policy.
We may update this Privacy Policy from time to time. Your continued use of our Services after any updates means that you accept those changes. We encourage you to review this page regularly for the latest information.
If you have any questions about this Privacy Policy, please contact us.
1. What Information Does Derivative Path Collect and What Are The Sources?
The personal information we collect depends on how you interact with us, the Services you use, and the choices you make. We collect personal information from the following sources:
A. Directly from You
You may provide personal information to us directly when you submit an inquiry or request information, subscribe to our newsletter, register for an event or create an account, contact a Derivative Path representative and engage in business with us.
Examples of the personal information we collect from you include the following:
- A first and last name
- Account name or alias, if registered
- An email address
- A telephone number
- Professional or employment-related information
- Any other information you choose to provide
If you engage in business with us, we may also request additional personal information for onboarding purposes. This may include, for example, information required to conduct anti-money laundering (AML) screening, in certain circumstances.
B. Automatically from Your Use of Our Services
When you visit our website or use our Services, we may automatically collect certain information using cookies, analytics tools, and similar technologies. This information helps us understand how users interact with our Services and improve functionality and performance.
For more information, including how you can manage your cookie preferences, please see our Cookie Policy.
C. From Third Parties
We may also collect personal information about you from third-party sources, such as business partners involved in providing our services or analytics providers.
2. How Does Derivative Path Use The Information We Collect?
We may use personal information for the following business purposes:
- To fulfill or meet the reason you provided the information (e.g., respond to inquiries)
- To provide, operate, support, personalize, and improve our website and Services
- To send service-related communications and marketing communications in accordance with your preferences
- To create, maintain, customize and secure your account with us
- To process your requests, transactions, detect and prevent fraud, and provide customer support
- To maintain the safety, security, and integrity of our systems, networks, and Services
- For internal testing, research, analytics, and product development
- To comply with legal obligations, court orders, or respond to law-enforcement or regulatory requests
- As otherwise described to you when collecting your personal information, or as permitted under applicable law
We do not use your personal information for profiling or automated decision-making that produces legal or similarly significant effects.
3. How Do We Share And Disclose Your Information?
We may disclose personal information to third parties for the following purposes:
A. For Business Purposes
We disclose personal information to third parties that help us operate, provide, and improve our Services. Such disclosures are governed by written contracts that:
- Specify the business purpose
- Require the recipient to keep the information confidential
- Prohibit using the information for any purpose other than performing the services on our behalf
Examples of such service providers include:
- Cloud storage or hosting providers
- Analytics service providers
- Security vendors
B. For Legal or Regulatory Compliance
We may disclose your personal information if required to do so by law, regulation, legal process, or governmental request, or to protect the rights, safety or property of Derivative Path, our customers, or others.
C. In the Event of a Business Transfer
We may use and/or transfer personal information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us about our users/consumers is among the assets transferred.
D. Cookies and Analytics
We may use cookies and similar technologies on our website to personalize content, analyze traffic, and deliver targeted advertisements. For more information, please refer to our Cookie Policy.
E. No Sale of Personal Information
We do not sell your personal information.
4. How Can You Control Our Use Of Your Information?
You may manage your information and preferences as follows:
- Marketing Preferences: You may manage your preferences for receiving marketing communications at any time. Each email we send includes a link to update your preferences or unsubscribe.
- Do Not Track: Our website is configured to recognize and honor certain browser-based opt-out signals. If your browser sends a “Do Not Track” (DNT) signal, or a Global Privacy Control (GPC) signal, we will honor that preference and not track your browsing behavior across websites where required by applicable privacy laws.
- Privacy Rights Requests: You may request access, correction, deletion, or restriction of your personal information by contacting: [email protected]. We will respond to your request in accordance with applicable privacy laws.
5. Privacy Policy For California Residents
If you are a California resident, you have specific rights under California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 regarding your personal information. Please review Appendix A for your additional rights.
6. Data Retention
We retain personal information only for as long as reasonably necessary to:
- Fulfill the purposes described in this Privacy Policy
- Comply with legal obligations
- Resolve disputes
- Enforce our agreements
Retention periods vary by category of information and are determined based on factors such as the length of our relationship with you, applicable legal requirements, and our legitimate business needs.
7. Security
We implement appropriate technical and organizational safeguards to protect personal information. These measures include:
- Limiting access to personal information to only those who need it
- Securing systems through encryption, firewalls, and monitoring
- Regularly reviewing and updating our security practices
However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security.
8. Third-Party Websites
Our website may contain links to third-party websites or services. This Privacy Policy does not apply to those third parties, and we are not responsible for their data practices. We recommend reviewing the privacy policies of any third-party sites you visit before providing them with your personal information.
9. Children
Our Services are not directed at, and we do not knowingly collect personal information from, individuals under the age of 16. If you are under 16, please do not use or provide any information on our Services. If we learn we have collected or received personal information from a minor under 16 without verification of parental consent, we will delete that information. If you are a parent or guardian and believe we might have any information from or about your child, please contact us at [email protected].
10. Changes to This Policy
We may update this Privacy Policy from time to time. The “Last Updated” date at the top of this page reflects the most recent changes. If we make material changes, we will notify you by posting the updated policy and, where required, provide additional notice.
11. Contact Us
If you have any questions or wish to exercise your rights, please contact:
Derivative Path, Inc.
2001 N. Main Street, Ste 250
Walnut Creek, CA 94596
T: 415-992-8200
E: [email protected]
Appendix A: Additional information for California Residents
This Appendix A supplements our Privacy Policy and applies only to California residents, in accordance with the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”). Any terms defined in the CCPA have the same meaning when used in this Notice. This Appendix does not apply to workforce-related personal information collected from California-based employees, job applicants, contractors, or similar individuals (see CCPA Employee Policy & Notice).
For the purposes of this Appendix, “personal information” means information that identifies, relates to, describes or could reasonable be linked, directly or indirectly with a particular consumer or household. This does not include publicly available, deidentified or aggregate information, or information otherwise excluded from the CCPA’s scope (such as data subject to HIPAA or GLBA).
1. Categories of Personal Information Collected
The table below identifies the categories of personal information we have collected, used, or disclosed in the preceding 12 months:
| Category | Examples | Collected |
| A. Identifiers | A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, or other similar identifiers. | YES |
| B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)) | A name, signature, Social Security number, physical characteristics or description, address, telephone number, education, employment, employment history, or any other financial information. Some personal information included in this category may overlap with other categories. | YES |
| C. Protected classification characteristics under California or federal law | Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information). | YES |
| D. Commercial information | Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | NO |
| E. Biometric information | Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data. | NO |
| F. Internet or other similar network activity | Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement. | YES |
| G. Geolocation data | Physical location or movements. | NO |
| H. Sensory data | Audio, electronic, visual, thermal, olfactory, or similar information. | NO |
| I. Professional or employment-related information | Current or past job history or performance evaluations. | YES |
| J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)) | Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records. | NO |
| K. Inferences drawn from other personal information | Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes. | YES |
2. Sources of Information
We collect personal information from the sources described in the “What Information Does Derivative Path Collect and What Are Our Sources?” section of our Privacy Policy.
3. Use And Disclosure
We use and disclose personal information for the business purposes described in the “How Does Derivative Path Use The Information We Collect?” and “How Do We Share and Disclose Your Information?” sections of our Privacy Policy.
In the preceding twelve (12) months, we have not sold or shared (for the purposes of cross-context behavioral advertising) any of your personal information.
In the preceding twelve (12) months, Company has disclosed personal information for a business purpose to the categories of third parties indicated in the chart below.
| Personal Information Category | Category of Third-Party Recipients | |
| Business Purpose Disclosures | Sales (or Sharing for Cross-Context Behavioral Advertising) | |
| A: Identifiers | Service providers; Business partners; Analytics providers; and Other parties you may authorize | None |
| B: California Customer Records personal information categories | Service providers; Business partners; Analytics providers; and Other parties you may authorize | None |
| C: Protected classification characteristics under California or federal law | Service providers; Business partners; Analytics providers; and Other parties you may authorize | None |
| D: Commercial information | Service providers; Business partners; Analytics providers; and Other parties you may authorize | None |
| E: Biometric information | None | None |
| F: Internet or other similar network activity | Service providers; Business partners; Analytics providers; and Other parties you may authorize | None |
| G: Geolocation data | None | None |
| H: Sensory data | None | None |
| I: Professional or employment-related information | Service providers; Business partners; Analytics providers; and Other parties you may authorize | None |
| J: Non-public education information | None | None |
| K: Inferences drawn from other personal information | Service providers; Business partners; Analytics providers; and Other parties you may authorize | None |
Reselling Personal Information
The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales. We have not engaged in the sale of personal information in the preceding twelve (12) months. If we ever decide to sell or share personal information in the future, we will update this Privacy Policy and our Notice at Collection before doing so, provide clear notice of your right to opt out, and offer a “Do Not Sell or Share My Personal Information” link.
4. Your Rights and Choices
The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.
Right to Know and Data Portability
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past twelve (12) months (the “right to know”). Once we receive your request and confirm your identity (see “Exercising Your Rights to Know, Delete, or Correct Personal Information”), we will disclose to you:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- If applicable, the categories of personal information we sold or shared for cross-context behavioral advertising, and the categories of recipients to whom each category of personal information was sold or shared.
- The categories of personal information we disclosed for a business purpose, and the categories of recipients to whom each category of personal information was disclosed.
- The specific pieces of personal information we collected about you (also called a data portability request).
Right to Delete
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity (see “Exercising Your Rights to Know, Delete, or Correct Personal Information”), we will review your request to see if an exception allowing us to retain the information applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
- Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
- Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
- Debug products to identify and repair errors that impair existing intended functionality.
- Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
- Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546, et seq.).
- Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
- Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
- Comply with a legal obligation.
- Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
We will delete or de-identify personal information not subject to one of these exceptions from our records and will direct our service providers to take similar action.
Right to Correct
You have the right to request that we correct inaccurate personal information that we maintain about you.
Exercising Your Rights to Know, Delete, or Correct Personal Information
To exercise your rights to know or delete described above, please submit a request by emailing us at [email protected] or completing our contact us form.
Only you, or someone legally authorized to act on your behalf, may make a request to know or delete related to your personal information. If you use an authorized agent to submit a request, we may require you to verify your identity directly with us or confirm that you provided the authorized agent permission to act on your behalf.
You may only submit a request to know twice within a twelve (12)-month period. Your request to know or delete must:
- Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information, which may include:
- Verifying your name and email address.
- Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. We will only use personal information provided in the request to verify the requestor’s identity or authority to make it.
Response Timing and Format
We will confirm receipt of your verifiable consumer request within ten (10) business days. If you do not receive confirmation within the ten (10)-day timeframe, please contact [email protected].
We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another forty-five (45) days), we will inform you of the reason and extension period in writing.
We will provide it by mail or electronically, at your choice.
Any disclosures we provide will only cover the twelve (12)-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance, specifically via email unless otherwise agreed.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
- Deny you goods or services.
- Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
- Provide you a different level or quality of goods or services.
- Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
- However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
Participation in such programs will not limit your other CCPA/CPRA rights or result in discriminatory treatment.
5. Other California Privacy Rights
California’s “Shine the Light” law (California Civil Code Section § 1798.83) permits users that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to [email protected].