Vector AIS, LLC (“Vector,” “we,” “our,” or “us”) values your privacy. This Privacy Policy (“Policy”) describes how Vector collects, uses, and discloses your personal information that we collect when you visit our website, www.vectorais.com (the “Site”), use our platforms, or other products and services that display or include a link to this Policy, including our fund administration and investor platform, Valence (“Valence”), or otherwise interact with the services available through our Site (collectively, the “Services”).The personal information we collect from you, and the ways in which we use and disclose that information depend on how you use our Services or otherwise interact or engage with us. For example, if you are a registered Valence user, you will have access to one or more portals or dashboards in your capacity as an individual investor or a representative of a business entity investor and we will collect personal information about you to register you for, and when you access and use, Valence. If you are a Valence user, we will collect certain personal information about you from our client who is the manager of the fund in which you have invested, and we will share certain of the personal information that you have provided with that client. By visiting the Site, or using any of our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Services and any dispute over privacy, is subject to this Policy and our Terms of Use, available at www.vectorais.com, including their applicable terms governing limitations on damages and the resolution of disputes.
Personal Information We Collect About You
Depending on how you interact with us, we collect information directly from you, automatically through your use of the Site and Services, and from other sources.
PERSONAL INFORMATION WE COLLECT DIRECTLY FROM YOU
The personal information we may collect from you includes:
- Contact Information. When you contact us, including when you sign up to learn more about Vector or inquire about our fund services solutions, we collect your name, title, email address, and phone number. We also collect information such as job title, company name, general location information such as region, city or state, and any other information you choose to provide.
- Registration and Profile Information. When you register for an account with us, including to use and access Valence, we collect information such as password, and any other information used in connection with accessing your account. You will also have the ability to add to and edit information in your profile, including telephone number, address, and organization name. As described below, under “Personal Information We Collect from Other Sources”, we will collect certain of the information that we need to create an account for you for our investor portals, including Valence, directly from our client, which is the manager of the fund in which you have invested.
- Government-Issued Identifiers. In some circumstances, we may collect information such as social security number, driver’s license, passport number, or other government-issued identification number.
- Financial Information. We may also collect information such as bank account details or other financial account information including user or member ID information.
- Communications and Interactions. If you communicate with us, including if you submit information using the forms on our Site or in the Services, we collect your name, email address and your comment, question or feedback.
- Preferences and Other Requests. When you participate in one of our surveys or questionnaires, we may collect information such as user satisfaction, feedback, or other information related to your use of our Services. We also may collect information about your preferences, including communications preferences and other preferences you provide when interacting with us.
INFORMATION WE COLLECT AUTOMATICALLY
We and our service providers automatically collect information related to your use of our Services and interactions with us and others, including through the use of cookies, web beacons, pixel tags, and other similar technologies. The information we and our service providers may automatically collect includes:
- Device and Browsing Information. We use cookies, pixel tags, and other similar tracking technologies to automatically collect information when you access or use our Services, such as IP address, general location information such as your region, state, and city, browser type, domain names, access times, pages views, date/time stamps, operating system, language, mouse clicks, mouse movements, scrolling activity, device type, unique ID, Internet service provider, referring and exiting URLs, and similar device and browsing information.
- Activities and Usage. We also collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, and time spent within the Services.
To the extent permitted by law, we may combine this information with other information that we have collected about you. For more information about our use of cookies and other similar technologies, please see the “Cookies and Other Tracking Mechanisms” section below.
PERSONAL INFORMATION WE COLLECT FROM OTHER SOURCES
If you are a registered user of Valence, we will collect certain personal information about you from our relevant fund manager client, which is the manager of the fund in which you have invested, including your name, date of birth, social security number, driver’s license or other identification number, passport number, bank or financial account number, and other bank account information.In addition, we may collect and receive personal information about you from other sources, such as data analytics providers, social networks, Internet service providers, and public databases.
How We Use Personal Information
We collect, use, disclose and otherwise process the personal information we collect about you for the following purposes:
- Services and Support. To provide and operate our Services, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, communicate with you about the Services, and for similar support purposes.
- Analytics and Improvement. To better understand how users access and use the Services and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop our Services and its features, and for internal quality control and training purposes.
- Marketing and Promotions. For marketing and promotional purposes. For example, to send you information about our Services or the services of affiliated or non-affiliated entities, such as newsletters and other marketing content, including information about Vector events, technologies, and new offerings, as well as any other information that you sign up to receive.
- Research and Surveys. To administer surveys and questionnaires, such as for market research or user satisfaction purposes.
- Planning and Managing Events. For event planning and management purposes, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services.
- Security and Protection of Rights. To protect the Services and our business operations, and to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use.
- Compliance and Legal Process. To comply with applicable legal or regulatory obligations, including as part of a judicial proceeding; to respond to a subpoena, warrant, court order, or other legal process; or as part of an investigation or request, whether formal or informal, from law enforcement or a governmental authority.
- Auditing, Reporting, and Other Internal Operations. To conduct financial, tax and accounting audits; audits and assessments of our operations, privacy, security and financial controls, risk, and compliance with legal obligations; our general business, accounting, record keeping and legal functions, and to maintain appropriate business records and enforce company policies and procedures.
- General Business and Operational Support. To assess and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and to administer our business, accounting, auditing, compliance, recordkeeping, and legal functions.
How We Disclose Information
We may disclose the information, including personal information, we collect for the purposes described above and as follows:
- Affiliates. We may disclose the information we collect from you to our corporate affiliates.
- Vendors and Services Providers. We may disclose the personal information we collect to vendors and service providers who perform functions on our behalf, such as IT and website hosting, marketing and marketing research providers, customer support, data storage, analysis and processing providers, auditors, consultants and legal counsel.
- Clients and Other Client Users. If you are a Valence user, we will share information with our clients who are the managers of the funds in which you have invested. In addition, certain of your information, including your name, email address and title, will be visible to other Valence users who are representatives of the same investor as you are.
- Marketing and Analytics Providers. We may also disclose your personal information, such as device and browsing, and activities and usage information, to marketing and advertising networks, data analytics providers, and other companies who provide marketing or analytics services on our behalf. For more information see the “Cookies and Other Tracking Mechanisms” section below.
We also disclose your personal information in the following circumstances:
- In Support of Business Transfers. If we or our affiliates are or may be acquired by, merged with, or invested in by another company, or if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may share or transfer the personal information we have collected from you with or to the other company. We may also disclose certain personal information as necessary prior to the completion of such a transaction or other corporate transaction such as a financing or restructuring, to lenders, auditors, and third-party advisors, including attorneys and consultants.
- Compliance and Legal Obligations. We may disclose personal information to comply with our legal and compliance obligations and to respond to the legal process. For example, we may disclose information in response to subpoenas, court orders, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
- Security and Protection of Rights. We may disclose personal information where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property and safety of others. For example, we may disclose personal information to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety or legal rights of any person or third party, or (iii) enforce, detect, investigate and take action in response to violations of our Terms of Use. We may also disclose information, including personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
- Aggregate and Non-Identifiable Information. Notwithstanding anything else in this Policy, we may share, use, disclose, and otherwise process aggregate and de-identified information related to our business and the Services with third parties for quality control, analytics, research, development, and other purposes.
- Other Disclosures. We may disclose personal information in other ways not described above that we notify you of or that we obtain your consent for.
Cookies and Other Tracking Mechanisms
We and our service providers use cookies, tags, and other similar tracking mechanisms to automatically collect and record information about your browsing activities and use of our Services. We use this information to, for example, analyze and understand how users access, use, and interact with our Site, as well to identify and resolve bugs and errors in our Services, and to assess secure, protect, optimize and improve the performance of our Services, to prevent fraud and protect our Services, as well as for targeted marketing and advertising purposes, for analytics purposes, and to personalize content in our Services.
Cookies. Cookies are alphanumeric identifiers that we transfer to your device’s hard drive through your web browser for record-keeping purposes. Some cookies allow us to make it easier for you to navigate our Services, while others are used to enable a faster log-in process, support the security and performance of the Services, or allow us to track activity and usage data within Services. To prevent cookies from tracking your activity on our Site, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Visitors to our Site who disable cookies will be able to browse the Site, but some features may not function.
Pixel Tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, and help us manage content and compile usage statistics. We may also use these in our emails to let us know when they have been opened or forwarded, so we can track response rates and gauge the effectiveness of our communications.
Analytics. We use tools, such as Google Analytics, which are operated by third party companies, to evaluate usage of our Site and Services. These third-party analytics companies use cookies, pixels, and other tracking technologies to collect data about our Services, and to provide us with reports and metrics that help us evaluate usage of our Services, improve our Site, and enhance performance and user experiences. To learn more about Google’s privacy practices, please review the Google Privacy Policy at https://www.google.com/policies/privacy/partners/. You can also download the Google Analytics Opt-out Browser Add-on to prevent your data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Targeted Advertising. We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to personalize content and display advertising within our Services, as well as to manage our advertising on third-party sites, mobile apps and online services. We may share certain information with these third-party ad companies, and we and they may use cookies, pixels tags, and other tools to collect usage and browsing information within our Services, as well as on third-party sites, apps and services, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information. We and these third-party ad companies use this information to provide you more relevant ads and content within our Services and on third-party sites and apps, and to evaluate the success of such ads and content.
Do Not Track. Currently, our Site and Services do not recognize “Do-Not-Track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt-out of targeted advertising by following the instructions in the “Your Choices – Industry Ad Program Choices” section below.
Your Choices
We make available several ways for you to manage your preferences and privacy choices. These include:
- Account and Profile Information. You may access, update, or correct your account and profile information by logging in to your account and updating your personal information.
- Contact Information. You can update certain personal information we maintain about you (e.g., name, email address, and phone number) by contacting us using the contact information provided below.
- Marketing and Other Communications. You can opt out of receiving marketing or other email communications from us by following the instructions provided in each email we send you.
We also disclose your personal information in the following circumstances:
Children’s Information
Our Services are not directed to children, and we do not knowingly collect any personal information from children under the age of thirteen (13). If we become aware that we have collected information from a child under 13 years old online, we will delete such information from our records.
External Links
Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites, and we suggest you read the privacy policies and terms on all such third-party websites before proceeding to those websites.
Security
We have implemented safeguards that are intended to protect the personal information that we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
Changes to This Policy
This Policy is current as of the date set forth above. We may change this Policy from time to time. We will post any updates to this Policy on our Site, so we suggest that you check here periodically for the most up-to-date version of our Policy. If we make material changes to how we collect, use and disclose the personal information we have previously collected about you, we will endeavor to provide you with notice, such as by posting prominent notice on our Site or within the Services.
Contact Us
This Policy is current as of the date set forth above. We may change this Policy from time to time. We will post any updates to this Policy on our Site, so we suggest that you check here periodically for the most up-to-date version of our Policy. If we make material changes to how we collect, use and disclose the personal information we have previously collected about you, we will endeavor to provide you with notice, such as by posting prominent notice on our Site or within the Services.
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