1. EFFECTIVE September 1, 2020
We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information that we obtain from our clients and investors in our funds, 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 a client or investor gives us on applications or other written communication and during telephone and in person meetings when the client applies to open an account or receive investment advice or provides a subscription document in connection with a fund investment (which information may consist of the client’s or investor’s identification and contact information, age, occupation, home address, email address, telephone number, financial information and goals, asset, income and expense profiles, risk tolerance, tax identification numbers, and such additional financial information as we need to provide our services to such client or investor); and
- Information generated by a client’s or an investor’s other service providers, such as brokerage and custodians, to service client or investor accounts (such as trade tickets, account statements, tax information reports, trade confirmations, confirmations of contributions and withdrawals and similar account information)
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.
3. 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 may 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 would use this information to operate, develop and improve our services.
4. USE AND DISCLOSURE OF INFORMATION
We share the information you provide to us to apply for a password with 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. In connection with 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.
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.
5. CONTROL OF YOUR PASSWORD AND PERSONAL INFORMATION
The Site contains a link to log in to the crosslink.sharesecurely.com (the “Sharesecure Site”), where you can access information about your investments in our funds. You are responsible for all actions taken with your Sharesecure Site 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 the Sharesecure Site.
Your information is stored on a cloud based system, which may be 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.
9. CONDITIONS OF USE
10. CHANGES TO THIS POLICY
If you have any additional questions, please feel free to contact us any time at firstname.lastname@example.org