The information we gather through our Site is protected by our general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information. Generally, we collect non-public personal information about our clients and investors from the following sources:
- Information we receive from clients or investors on applications or other forms, including the information we collect on the Site, and
- Information about clients’ or investors’ transactions with us, our affiliates or others.
- Our policy is that:
- We do not disclose any non-public personal information about any user of our Site, our clients or investors or former clients or investors to anyone, except as permitted by law. We may voluntarily disclose non-public personal information about our users, clients or investors (including former clients or investors) to regulatory authorities in connection with our business or the business of our affiliates. In addition, we share non-public personal information with certain service providers, to the extent permitted by law, and we require those service providers to keep the non-public information confidential. For example, we may provide such information to prime brokers, ISDA counterparties, attorneys, third-party marketing firms, fund administrators and auditors.
- We restrict access to non-public personal information about our users, clients and investors to employees and service providers who need to know that information to provide services to our clients.
- We maintain physical, electronic and procedural safeguards that comply with federal standards to guard clients’ and investors’ personal information.
COLLECTION OF INFORMATION
In general, you can browse the non-password protected sections of the Site without telling us who you are or revealing any personal information about yourself. We automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language, one or more files that may uniquely identify your browser and most recent URL from which you came to our Site. We may use this information to do internal research on our users’ demographics, interests and behavior to better understand, protect and serve you and our clients.
We also may use data collection devices such as “cookies” on certain pages of the Site to help analyze our web page flow, measure effectiveness, and promote trust and safety. “Cookies” are small files placed on your hard drive that assist us in providing our services. We may offer certain features that are only available through the use of a “cookie.” Cookies can also help us provide information that is targeted to your interests. Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Site and you may be required to reenter your password more frequently during a session.
If you apply for a password to access password-restricted areas on this Site, you must provide to us your name, email address, and any other financial, investment or other information we request.
USE & DISCLOSURE OF INFORMATION
You agree that we may use personal information about you to analyze Site usage, improve our content and product offerings and customize the Site’s content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Site.
We may also share information about you if we believe that disclosure is required under law. For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.
PERSONAL INFORMATION & YOUR DATA PROTECTION RIGHTS
You have the right to review and change or complete the information you provide to us by contacting us at firstname.lastname@example.org. You must promptly update your personal information if it changes or is inaccurate.
On your request, we will deactivate your password and remove your contact information and financial information from our active databases. To make this request or if you have any questions about our use of your personal information, email email@example.com.
Your information is stored on our servers located in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure, which may include encryption, “firewalls” and Secure Socket Layers.
It is possible, however, that a third party will circumvent such security measures, and we do not guarantee that our security measures will successfully prevent third parties from accessing the information we collect. In the event of a security breach involving your personal information, we will make any legally required disclosures to you in the most expedient time possible and without unreasonable delay, consistent with the legitimate interests of law enforcement, or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your username, password, credit card information or national identification number in an unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Persons under the age of 18 are not eligible to use the Site. Therefore, we do not knowingly collect any personal information from persons under the age of 18.
CONDITIONS OF USE
CHANGES TO THIS POLICY
If you have any additional questions, please feel free to contact us any time at firstname.lastname@example.org.