Categories of Sources of Personal Data
o When you provide such information directly to us.
§ When you use our Site.
§ When you voluntarily provide information in free-form text boxes through the Site or
through responses to surveys or questionnaires.
§ When you send us an email or otherwise contact us.
§ We may use analytics providers to analyze how you interact and engage with the Site,
or third parties may help us provide you with customer support.
Our Commercial or Business Purposes for Collecting or Disclosing Personal Data
· Providing, Customizing and Improving the Site
o Providing you with the information you request.
o Meeting or fulfilling the reason you provided the information to us.
o Improving the Site, including testing, research, internal analytics and product development.
o Doing fraud protection, security and debugging.
o Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws, such as the California Consumer Privacy Act, as amended by the California Privacy Rights Act of 2020.
· Corresponding with You
o Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about us or the Site.
o Sending emails and other content according to your preferences or that display content that we think will interest you.
· Meeting Legal Requirements and Enforcing Legal Terms
o Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
o Protecting the rights, property or safety of you, us or another party.
o Enforcing any agreements with you.
o Responding to claims that any posting or other content violates third-party rights.
o Resolving disputes.
We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.
3. How we Share Your Personal Data.
We disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.
- Service Providers. These parties help us provide our services or perform business functions on our behalf. They include:
- Hosting, technology and communication providers.
o Security and fraud prevention consultants.
o Analytics providers.
· Business Partners. These parties partner with us in offering various services. They include:
o Businesses that you have a relationship with, including our investment fund affiliates
- Parties You Authorize, Access or Authenticate
- Third parties you access through the services.
We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.
All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.
Data that is Not Personal Data
We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.
4. Tracking Tools and Opt Out.
We use the following types of Cookies:
· Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Site such as by collecting information about the number of visitors to the Site, what pages visitors view on our Site and how long visitors are viewing pages on the Site. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Site’s content for those who engage with our advertising.
· Other Cookies. From time to time, our hosting provider may leverage other types of cookies in order to provide us with services. Those cookies will be described in the section of our website where you may opt in and out of cookies.
You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Site and functionalities may not work.
To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking the blue circle logo in the bottom left corner of your browser. To find out more information about Cookies, including information about how to manage and delete Cookies, please visit https://ico.org.uk/for-the-public/online/cookies/ or http://www.allaboutcookies.org/.
5. Data Security.
We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, and administrative security measures and storage and processing practices based on the type of Personal Data.
Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data or storing data over the Internet is completely secure. We cannot guarantee the complete security of any data you share with us, and except as expressly required by law, we are not responsible for the theft, destruction, loss or inadvertent disclosure of your information or content.
6. Data Retention.
We retain Personal Data about you for as long as necessary to provide our Site and/or services to you, comply with our legal obligations, resolve disputes, or as otherwise permitted or required by applicable law, rule or regulation. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data.
For example, we retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively, and efficiently. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.
7. Personal Data of Minors.
We do not knowingly collect or solicit Personal Data about children under 13 years of age, except with parental consent. If we learn that we have collected personal information from an individual under the 13 years of age without parental consent, we will delete such information as quickly as possible. If you believe that a child under 13 years of age may have provided Personal Data to us, please contact us at email@example.com.
8. Privacy Rights of California Residents.
You have the right to request certain information about our collection and use of your Personal Data over the past 12 months, including the:
· Categories of Personal Data that we have collected about you.
· Specific pieces of Personal Data that we have collected about you.
· Categories of sources from which that Personal Data was collected.
· Business or commercial purpose for collecting your Personal Data.
· Categories of third parties with whom we have shared your Personal Data.
· Categories of Personal Data shared with third parties for a business purpose over the past 12 months, if applicable.
You have the right to request that we delete the Personal Data that we have collected about you, subject to certain exceptions under the CPRA: for example, we may need to retain your Personal Data to provide you with the Site or services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.
You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CPRA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.
Exercising Your CPRA Rights
To exercise the rights described above, you must send us a request that (1) provides sufficient information to allow us to verify that you are either the person about whom we have collected Personal Data or are an agent authorized by that person, and (2) describes your request in sufficient detail to allow us to understand, evaluate and respond to it. Each request that meets both of these criteria will be considered a “Valid Request.” We may not respond to requests that do not meet these criteria. We will only use Personal Data provided in a Valid Request to verify your identity and complete your request. You may submit a Valid Request by emailing us at firstname.lastname@example.org.
We will work to respond to your Valid Request within 45 days of receipt. We will not charge you a fee for making a Valid Request unless your Valid Request(s) is excessive, repetitive or manifestly unfounded. If we determine that your Valid Request warrants a fee, we will notify you of the fee and explain that decision before completing your request.
You may also authorize an agent (an “Authorized Agent”) to exercise your rights on your behalf. To do this, you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf.
We Do Not Sell Your Personal Data
We will not “sell” your Personal Data, as that term is defined in the CPRA, and have not done so over the last 12 months. We also do not sell the Personal Data of minors under 16 years of age.
Personal Data Sharing Opt-Out and Opt-In
Under the CPRA, California residents have certain rights when a business “shares” Personal Data with third parties for purposes of cross-contextual behavioral advertising. We do not do cross-contextual behavioral advertising.
We Will Not Discriminate Against You for Exercising Your Rights Under the CPRA
We will not deny you access to our Site or provide you a lower quality of services if you exercise your rights under the CPRA. If you have any questions about this section or whether any of the above rights apply to you, please contact us at email@example.com.
14. Privacy Rights of Other United States Residents.
California Resident Rights
California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes, under California Civil Code Sections 1798.83-1798.84. If you would like to submit such a request, please contact us at firstname.lastname@example.org.
Nevada Resident Rights
If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. If you are a Nevada Resident, you can exercise this right by contacting us at email@example.com with the subject line “Nevada Do Not Sell Request” and providing us with your name. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A.
17. Contact Information.
o When you use the Site and such information is collected automatically.
§ Through Cookies (defined in the “Tracking Tools and Opt-Out” section below).