1. What information do we collect from you?
2. Where do we collect information from you and how do we use it?
3. With whom do we share your information?
4. How can you update, correct or delete your Personally Identifiable Information?
5. What are your choices regarding collection, use and distribution of your information?
6. What security precautions are in place to protect against the loss, misuse or alteration of your information?
7. Do we use "cookies"?
8. What should you know about privacy policies and data collection at any third party sites accessible from the Website and Content?
9. What else should you know about your privacy online?
We collect two types of information about our users: Personally Identifiable Information and Non-Personally Identifiable Information. Our primary goal in collecting information from you is to provide you with a smooth, efficient, and customized experience while using the Website and Content.
Personally Identifiable Information: This refers to information that lets us know the specifics of who you are. When you engage in certain activities on the Website and Content, such as sending us a message message from the “Contact Us” area of the Website, or making an investment, we may ask you to provide certain information about yourself by filling out and submitting an online form or by downloading and printing a paper form and sending it to us. It is completely optional for you to engage in these activities. If you elect to engage in these activities, however, we may ask that you provide us personal information, such as your first and last name, mailing address (including zip code), email address, telephone and facsimile numbers, and other personal identifying information. When investing directly on the Website (not yet available), you may be asked to provide a credit card number and other investment-related personal information. Depending upon the activity, some of the information we ask you to provide is identified as mandatory and some as voluntary. If you do not provide the mandatory data with respect to a particular activity, you will not be able to engage in that activity.
Non-Personally Identifiable Information: This refers to information that does not by itself identify a specific individual. We gather certain information about you based upon where you visit on the Website and Content in several ways. This information is compiled and analyzed on both a personal and an aggregated basis. This information may include the Uniform Resource Locator ("URL") of the web site that you just came from, which URL you go to next, what browser you are using, and your Internet Protocol ("IP") address. An URL is the global address of documents and other resources on the World Wide Web. An IP address is an identifier for a computer or device on a Transmission Control Protocol/Internet Protocol ("TCP/IP") network, such as the World Wide Web. Networks like the Web use the TCP/IP protocol to route information based on the IP address of the destination. In other words, an IP address is a number that is automatically assigned to your computer whenever you are surfing the web, allowing web servers to locate and identify your computer. Computers require IP addresses in order for users to communicate on the Internet.
We do not collect any Personally Identifiable Information about you unless you voluntarily provide it to us.
In addition, we may also collect, or our third party ad server(s) may collect, certain Non-Personally Identifiable Information. This information is ultimately stored in the form of store categories, and, in some cases, specific URLs. We use your IP address to diagnose problems with our servers, software, to administer the Website and to gather demographic information. If you clicked on an advertisement that our third party ad server posted on another website, then they may provide us with your IP address, what ad you clicked, what website you clicked from and other Non-Personally Identifiable Information enabling us to determine the effectiveness of our advertising.
We will primarily use your Personally Identifiable Information to provide our services to you, as required by our agreements with you. If you invest, then your Personally Identifiable Information will be maintained in our investor records. We may also use Personally Identifiable Information to resolve disputes, troubleshoot problems and enforce our agreements with you, including our Website Terms and Conditions of Use, and this Private Policy.
We do not sell, trade, or rent your Personally Identifiable Information to others. We may provide some of our services through contractual arrangements with affiliates, services providers, partners and other third parties (collectively “service partners”). We and our service partners use your Personally Identifiable Information to operate the Website and to deliver the Content. For example, when we implement online investment (not yet available), if you invest online, we will need to release your credit card information to a banking service partner to confirm your payment.
We encourage our service partners to adopt and post privacy policies. However, the use of your Personally Identifiable Information by our service partners is governed by their respective privacy policies, and is not subject to our control.
Occasionally we may be asked by law enforcement or judicial authorities to provide Personally Identifiable Information to the appropriate governmental authorities. We may disclose Personally Identifiable Information if a court order, search warrant or subpoena is served on us.
We may also provide Non-Personally Identifiable Information about our customers' sales, traffic patterns, and related Website information to advertising and marketing service partners, but these statistics do not include any Personally Identifiable Information.
If you invest and your Personally Identifiable Information subsequently changes, you should promptly contact us so we can update our investor records.
This website does not yet (but may in the future) support personalized accounts of registered users to which they can login. Consequently, at that time no Personally Identifiable Information arising from such accounts is stored on the Website.
We may, from time to time, send you emails not directly related to your transactions with us, but that we feel might be of interest to you. If you do not want to receive such emails from us, you may tell us when you give us your personal information. Or, at any time you may notify us that you no longer wish to receive such emails.
You also have choices with respect to cookies, as described below. By modifying your browser preferences, you may have the choice to accept all cookies, to be notified when a cookie is set, or to reject all cookies. If you choose to reject all cookies some parts of the Website and Content may not work properly for you.
At the Website, you can be assured that your Personally Identifiable Information is secure, consistent with current industry standards. The importance of security for all Personally Identifiable Information associated with our user is of utmost concern to us.
Information that you provide that is not Personally Identifiable Information also resides on a secure server and is only accessible via password.
When online investing is implement (not yet available), if you invest online, credit card transactions will be handled by established third party banking, processing agents and distribution institutions. They will receive the information needed to verify and authorize your credit card or other payment information and to process and ship your order.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be 100% secure. As a result, while we strive to protect your Personally Identifiable Information, you acknowledge that: (a) there are security and privacy limitations of the Internet which are beyond our control; (b) the security, integrity and privacy of any and all information and data exchanged between you and us through the Website cannot be guaranteed; and (c) any such information and data might be viewed or tampered with in transit by an unauthorized third party.
When you use the Website and Content we will store cookies on your computer in order to facilitate and customize your use of the Website and Content. A cookie is a small data text file, which a Website stores on your computer's hard drive (if your web browser permits) that can later be retrieved to identify you to us. Our cookies store randomly assigned user identification numbers and the country where you are located. The cookies make your use of the Website and Content easier, make the Website and Content run more smoothly and help us to maintain a secure Website. You are always free to decline our cookies if your browser permits, but some parts of the Website and Content may not work properly in that case.
You must be at least 18 years old to have our permission to use the Website and Content. Our policy is that we do not knowingly collect, use or disclose Personally Identifiable Information about visitors that are under 18 years of age.