Last Updated: November 2022
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.
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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
- 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.
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.
- 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.
- 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
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.
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.
- Industry Ad Program Choices. You can also control how participating third-party ad companies use the information that they collect about your visits to our Services, and those of third parties, in order to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad companies at aboutads.info/choices (Digital Advertising Alliance). You may also download the DAA AppChoices (https://youradchoices.com/appchoices) tool in order to help control interest-based advertising on apps on your mobile device. Please note that opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or ‘contextual’ ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.
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.
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.
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.
If you have questions or concerns about this Policy or our privacy practices, you may contact us via any of the methods described below:
- Email: firstname.lastname@example.org
- Phone: +1 (415) 449-4411