We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information, and the information we gather over the Site 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 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 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 clients or investors or former clients or 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 prime brokers, ISDA counterparties, attorneys, third-party marketing firms, 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 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 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 Site or not), which URL you next go to (whether this URL is on the Site or not), your computer browser information and your IP address. We use this information to operate, develop and improve our services.
If you apply for a password to access any password-restricted areas on this Site, you must provide to us your name, mailing address, email address, phone number, personal financial data, investment portfolio and other investment information.
USE AND DISCLOSURE OF INFORMATION
We share the information you provide to us to apply for a password with [us, or _____________ (the “Administrator), which administers the Site and provides certain other services to us]. This sharing of information is necessary to administer the Site. [If needed: Our contract with the Administrator requires, among other things, that it will not disclose or use your personal information other than to perform these services for us.] We may use your information to send correspondence and perform services on your behalf in connection with investment related activities.
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.
PASSWORD-PROTECTED AREAS OF SITE: CONTROL OF YOUR PASSWORD AND PERSONAL INFORMATION
If you obtain credentials to access a password-protected area of the Site, you are responsible for all actions taken with your user name and password. Therefore, we recommend that you do not disclose your password to any third parties. You may not allow others to use your user name or password to access or use any part of this Site. If your password has been compromised for any reason, you should contact us immediately for a new password.
You can review and change the information you submit to us by contacting us at firstname.lastname@example.org. On the Site, you can change your User ID, email address, contact information, financial information, other personal information and user preferences. 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, 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 or theft as well as 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.
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.
Children (persons under the age of 18) are not eligible to use the Site and, 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.