Privacy Policy

Last modified: August 10th, 2020

Introduction

• On the Website.
• In email, text, and other electronic messages between you and the Website, including through third-party services used by the website to provide technical, customer, and sales support functions. 
• Offline or through any other means, including on any other websites operated by the Company (including our affiliates and subsidiaries).

• Identifiers. Legal name, postal address, email address, telephone number, password, social security number, birthdate, marital status, tax identification number, bank account information, driver’s license number, passport number, or copies of ID cards or other forms of identification. 
• Contact Information. Residence address, principal place of business address, email address, and telephone numbers. 
• Financial/Transaction Information. Bank account information, payment, and/or billing details.
• Investment Information. Investment objectives, prior investment experience, prior investment activity and documentation, andservice-related investment terms and information. 
• Communications. Email or Website based communications and responses.
• Content. Any content which you provide to be published or displayed (hereinafter, “posted”) on the Website, including but not limited to account profiles, preference settings, and other contributions. 
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code Section 1798.0(e)): Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, bank account number.
• Internet or other similar network activity. Internet protocol (IP) address, your login information, browser type and version, the equipment you use to access our Website, and usage details. 

• Directly from you when you provide it to us.
• Automatically as you navigate through the Website. Information collected automatically may include usage details, IP addresses, and information collected through cookies, web beacons, and other tracking technologies.
• From third parties, for example, our customers, business partners, and third-party services used by the website to provide technical, customer, and sales support functions. 

• Information that you provide by filling in forms or posting materials on the Website. This includes information provided at the time of registering to use the Website, creating or updating account profiles, and posting documents and other materials. We may also ask you for information when you report a problem with the Website. 
• Records and copies of your correspondence (including email addresses). 
• Your responses to surveys that we might ask you to complete for research purposes. 

• Details of your visits to the Website, including traffic data, location data, logs, and other communication data and the resources that you access and use on the Website. 
• Information about your computer and internet connection, including your IP address, operating system, browser type, and crash data. 
• The information we collect automatically may include personal information. Such information helps us to improve the Website and to deliver better and more personalized services, including by enabling us to:
• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize the Website according to your individual interests. 
• Speed up your searches.
• Recognize you when you return to the Website. 

• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of the Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to the Website.
• Web Beacons. Pages of the Website and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related statistics (for example, recording the popularity of certain content and verifying system and service integrity). 
• Third Party Services. We may use third-party services such as Google Analytics and Mailgun to help understand your use of the Website. 
  • Google Analytics. This Website uses Google Analytics to help analyze how users use the site. Google Analytics is a web analytics service. Web analysis is the gathering, collection and analysis of data about the behavior of visitors to websites. Further information and Google’s applicable privacy policies can be found here. 
    • Opting Out: You may set preferences by utilizing the Google Analytics Opt Out Browser add on available here.

     

  • Mailgun. This Website uses Mailgun as a provider of email services, which also provides a web beacon to analyze when users open or view email messages sent through the Website. Further information and Mailgun’s applicable privacy policies can be found here. 
  • Hotjar. This Website uses Hotjar to help analyze how users use the Site. Hotjar is a web analytics service. Hotjar uses cookies and other technologies to collect data on our users’ behavior and their devices, including pages visited, actions which are taken, IP address, device screen size, device type, browser information, operating system, and geographic location (country only). Hotjar does not track your browsing habits across websites which do not use Hotjar services. Further information and Hotjar’s applicable privacy policy can be found here. 

   

• To present the Website and its contents to you. 
• To provide you with information, products, or services that you request from us. 
• To fulfill any other purpose for which you provide it. 
• To provide you with notices about your user and account registration. 
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, or between us and our customers.
• To notify you about changes to the Website or any products or services we offer or provide through it, including important services-related notices, updates to our privacy policy and Terms of Use. 
• To allow you to participate in interactive features on the Website. 
• In any other way we may describe when you provide the information. 
• For any other purpose with your consent. 

• To Company employees in order to fulfill their duties. 
• To our subsidiaries and affiliates to fulfill their duties, including to help us develop, maintain and provide our services.
• To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
• To our lawyers, accountants, bankers, auditors, insurers, and other professional advisers we use to provide legal, compliance, accounting, banking, insurance, and other similar services. 
• To customer’s authorized users and designated representatives of our customers who may be able to add, modify or restrict access. An example is a fund manager designee who adds third-party access to a user’s investment profile(s). 
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the Company’s assets, whether as a going concern or as a part of bankruptcy, liquidation, or similar proceeding, in which personal information held by the Company about the Website users is among the assets transferred. Any such buyer or successor will be required to comply with reasonable confidentiality restrictions with respect to personal information. 
• To fulfill the purpose for which you provide it. For example, if you provide us a tax identification number, we will use it to create and distribute to you a schedule K-1 tax document. 
• For any other purpose disclosed by us when you provide the information. 
• With your consent. 

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• To enforce or apply our terms of service and other agreements, including for enforcing contracts or policies, reporting on security breaches, or assisting with investigating and preventing fraud or security incidents. 
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others. 

• Identifiers.
• Personal information categories listed in the California Customer Records statute (Cal. Civ. Code Section 1798.0(e)).

• ●Access to Specific Information and Data Portability Rights. You have the right to request a statement about our collection of your personal information over the past twelve (12) months. Upon receipt of a verifiable user request, we will disclose to you the categories of personal information collected, our business or commercial purpose for collecting that information, any third-parties who we have disclosed such information if we sold or disclosed any personal information for a business or commercial purpose. 
• ●Deletion Request Rights. You have the right to request that we delete your personal information, subject to certain exceptions. Upon receipt of a verifiable user request, we will delete (and direct any third parties who we have disclosed such information to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retention of the information is required for us to complete the transaction for which we collected the personal information, detect, protect, and prosecute against illegal activity, debug and repair products, and comply with a legal obligation. 

• Access Your Personal Data. You have the right to obtain a copy of the information collected by us. 
• Rectification. You have the right to request the modification of your information, including the correction of errors and updating of incomplete information. 
• Erasure. You have the right to deletion or removal of your personal information from the Website or any other records in which it is stored when such information is no longer necessary in relation to the purpose it was collected. You also have the right to request deletion where you have exercised your right to object to processing. 
• Restrict Data Processing. You have the right to request that all processing of your information be stopped to (1) contest the accuracy of such information; (2) where such information processing is unlawful; (3) where the Controller/Processor no longer needs the information for processing, (4) or where you have exercised your right to object to processing. 
• Notification. You have the right to be notified about the uses of your personal information including any rectification, erasure, or restriction of processing. 
• Data Portability. You have the right to receive the personal information provided to us through automated means, in a structured, commonly used machine-readable format, or to have that information transmitted to another controller.
• Objection. You have the right to object to the processing of your personal information where we are relying on legitimate interest as the legal basis for our processing and there is something about your particular situation, which makes you want to object to the processing of your information. You also have the right to object where personal information is processed for direct marketing purposes. 
• Reject Automated Individual Decision-Making. You have the right not to be subject to a decision based solely on automated processing, including profiling unless subject to the creation or performance of a contract or such processing is based on your explicit consent. 
• Withdraw Consent. You have the right to withdraw consent where we are relying on consent to process your information. If you withdraw consent, we may not be able to provide you with full access to the Website or services related to its functionalities. We will provide you with a notification at the time you withdraw consent.