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.
Use and disclosure of information
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.
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.
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 email@example.com. Your password will be deactivated promptly based on your account activity and in accordance with our deactivation policy and applicable law.
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.
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 (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
Change to this policy
If you have any additional questions, please feel free to contact us any time at firstname.lastname@example.org.