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In this case, I think the "services" they are providing in conjunction with this offering would be to MasterCard, Apple, and the cardholder, so I don't thing they would be constrained with regard to anything else for /this data/. Though, I think it really depends on the agreements between MasterCard and Apple, about what data would be considered "misappropriated" though (see sweeneyrod's link[1]).

They still couldn't /legally/ trade on things like "companyX asked us for a loan, so let's buy/short/etc companyX before they announce it", as that would be servicing companyX directly, and they learned the information (about the loan) from that servicing.

[1]: https://news.ycombinator.com/item?id=20729529



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