Overview

We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information, and the information we gather over the Website is protected by those policies and procedures. 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 Website, 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 our current or former clients and investors to anyone, except as permitted by law. We may voluntarily disclose non-public personal information about such clients and investors to regulatory authorities in connection with our business or our affiliates (such as any of our funds). 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 attorneys, fund administrators and auditors.
• We restrict access to non-public personal information about our 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 Website 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 and one or more files that may uniquely identify your browser. 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. This information may include the URL that you just came from (whether this URL is on the Website or not), which URL you next go to (whether this URL is on the Website or not), your computer browser information and your IP address. We use this information to operate, develop and improve our services.

We also may use data collection devices such as “cookies” on certain pages of the Website 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 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 Website and you may be required to reenter your password more frequently during a session. We use cookies to better understand how people interact with us.

Use and disclosure of information

We use the information we collect from our browser and data collection devices such as cookies to improve our operations and facilitate, and improve, the services you request. We may use information collected from you to measure interest, customize your experience and enforce our Terms of Use.

We may use personal information about you to analyze Website usage, improve our content and product offerings and customize the Website’s content, layout, and services. These uses improve the Website and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Website.

In providing our services, it also may be necessary for us to share personal information about you with other third parties to help us process transactions relating to your account, including, but not limited to, asset transfers from a financial institution and processing or administering investment transactions and portfolios. In certain instances, we may contract with third parties that are not affiliated with us to perform services for us, and, if necessary, we may disclose information about you to those third parties solely for the purpose of carrying out their assigned responsibilities. In those circumstances, we require those third parties to treat your private information with the same degree of confidentiality that we do. In some instances, the third-party service provider may collect information directly from you. In these cases, you will be notified of the involvement of the service provider, and all additional information you provide them and their additional uses will be strictly up to you. If you provide additional information to a service provider directly, their use of your personal information is governed by their applicable privacy policy. us.

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.

We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy. For example (and without limiting the foregoing), we may be forced to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or service providers may abuse or misuse your personal information that they collect from the Website. Therefore, although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private

Control of your password and personal information

You are responsible for all actions taken with your username and/or password. Therefore, you should not disclose your password to any third parties. You may not allow others to use your username or password to access or use any part of this Website. If your password has been compromised for any reason, you should contact us immediately for a new password, or, if applicable, change your password using the “Trouble Logging In” link on the Client Login page.

You must promptly contact us directly to 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, email info@schoolcraftcapital.com. Your password will be deactivated promptly based on your account activity and in accordance with our deactivation policy and applicable law.

We will retain in our files the personal information you have asked us to remove from our active databases to prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use and comply with legal requirements. Therefore, your personal information will not be completely removed from our databases in response to your requests. However, such personal information will only be available to select employees, service providers and governmental persons or entities.

Security

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, theft and unauthorized access and disclosure to protect your privacy, which may include encryption, “firewalls” and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the company.

A third party may, however, circumvent such security measures, and our security measures may not 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.

Phishing

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.

Children

Children (persons under the age of 18) are not eligible to use the Website and, therefore, we do not knowingly collect any personal information from persons under the age of 18.

Condition of use

If you choose to visit the Website, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages and application of the law of the State of Colorado. If you have any concern about privacy, please send a thorough description to info@schoolcraftcapital.com.

Change to this policy

We may amend this Privacy Policy at any time by posting the amended terms on the Website. All amended terms shall automatically be effective 30 days after they are initially posted on the Website. Your continued use of the Website constitutes your agreement to this Privacy Policy and any changes to it. If we make any material changes to this Privacy Policy that affect your information already stored in our database, we will post a prominent notice on the Website stating that this Privacy Policy has changed. If you do not agree with this Privacy Policy or any changes to it, please do not use or access the Website.

If you have any additional questions, please feel free to contact us any time at info@schoolcraftcapital.com.