Effective Date: September 14, 2020
Please keep in mind that certain information submitted to the Platform is publicly visible to other users within the Platform. For example, investor or allocator users may be able to view managers’ performance data in the Platform, and manager users may be able to view investors’ or allocators’ investment preferences in the Platform.
DATA WE COLLECT
“Personal Data” means information that can be used to identify you, and may include your name, email address, phone number, mailing address, birthdate, photograph, etc. We collect Personal Data that you voluntarily provide us, for example when you register a user account, sign up for mailing lists or newsletters, register or pay for an event, verify your eligibility as an investor or manager, or otherwise reach out to us. Your submission of Personal Data is voluntary, but we may be unable to provide you requested information or services if you choose not to provide necessary Personal Data.
The Platform may offer you the ability to log in with, or otherwise connect, your third-party social media accounts. If you choose to use such social media accounts in this manner, you agree that we and the applicable third-party social media provider may exchange Personal Data to fulfill the purpose of the connection.
“Other Information” means information that does not identify you personally, and may include technical details regarding the device you use to access the Platform, IP address, operating system, browser, referral URLs, page views, location data (if location services are enabled), clicks, etc. Our systems automatically collect this kind of Other Information when you interact with the Platform. Other Information also includes information that may originally have been Personal Data but has been aggregated or anonymized such that it cannot be used to identify any individual.
COOKIES AND SIMILAR TECHNOLOGY
We use “cookies” to obtain certain types of data when your web browser accesses our website. Cookies are alphanumeric identifiers that we transfer to your computer's hard drive through your web browser to enable our system to recognize you and your personalized settings, to better understand how you interact with the Platform, to monitor aggregate usage, and to optimize web traffic routing on our website. Most browsers have settings to disable or limit cookies, but please note that certain areas or features of the Platform may not be available or fully-functional if you choose to disable cookies for our websites. We may also use pixel tags, web beacons, or similar technologies to understand how our users interact with our sites and emails. Our website does not respond to “do not track” signals.
USE OF YOUR DATA
We use your Personal Data:
You can opt out of receiving promotional or marketing emails from us at any time by clicking the unsubscribe, opt-out, or similar link at the bottom of any such emails. Please note we may still contact you in connection with your account or any transactions involving you.
We may use Other Information (which does not identify you personally) for any manner we deem appropriate, including without limitation to improve, maintain, and operate the Platform.
DISCLOSURE OF YOUR DATA
We will not sell your Personal Data to third parties. We may share your Personal Data with our affiliates and as needed to fulfill the purposes described in the “USE OF YOUR DATA” section above, including:
Additionally, in the event of a merger, consolidation, sale, or transfer of all or substantially all of our assets or business, one of the assets that would generally be transferred is the data we have collected, which would be transferred subject to the applicable version of this Policy.
We may disclose Other Information (which does not identify you personally) to any parties and for any purposes we deem appropriate.
LOCATION; DATA RETENTION, ACCESS, AND CORRECTION; SECURITY
We are based in the United States. By using the Platform, you consent to your Personal Data being transferred to and stored in the United States. We may retain your data so long as we can reasonably foresee the data may be required in connection with our business relationship with you. In some cases, we will retain the data for a longer period as necessary to comply with our legal obligations, follow records retention policies, resolve disputes, and enforce our agreements. You may access and update your Personal Data by visiting your account profile.
We have implemented reasonable physical, organizational, and technical procedures to secure the Personal Data we have in our possession. Unfortunately, no measures can be guaranteed to provide 100% security when dealing with internet connections.
YOUR CALIFORNIA PRIVACY RIGHTS
California law entitles California residents to certain additional protections regarding Personal Data. For purposes of this section alone, “CCPA Personal Information” means any information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household.
We will not discriminate against you if you choose to exercise any of these rights. To make any of the above requests, please contact us as set forth at the end of this Policy. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee to the extent permitted by law.
YOUR EUROPEAN UNION AND SWISS PRIVACY RIGHTS
If you are a European Union or Swiss resident, applicable data protection laws may provide you with certain rights with regards to our processing of your Personal Data. To the extent established under applicable law, European Union or Swiss residents may have the right:
To make any of the above requests, please contact us as set forth at the end of this Policy. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Data, you may be charged a fee to the extent permitted by law.
The Platform is not directed toward children under 13. If a parent or guardian becomes aware that his or her child has provided us with personal information, the parent or guardian should contact us as set forth at the end of this Policy, and we will take reasonable steps to promptly remove such data from our systems (subject to any applicable, legally required or permitted, retention standards).
THIRD PARTY SITES
For more information or for help in answering any questions, please contact us at firstname.lastname@example.org.