Privacy Policy
Allocations Privacy Policy
Effective as of: November 20, 2022
1. Introduction - Who We Are
(1) Allocations Fund Administration LLC ("Company" or "We") respects your privacy and is committed to protecting it through our compliance with this policy. We are also committed to protecting your privacy in accordance with the principles laid out in the applicable legislation. This policy describes the types of information we may collect from you or that you may provide when you use our website, applications or services (our "Service" or "Website") and our practices for collecting, using, maintaining, protecting, and disclosing that information.
This policy applies to information we collect:
(a) on this Website or Service; and/or
(b) in email, text, and other electronic messages between you and this Service; and/or
(c) as may be provided to the Company by you, or at your request by a third-party.
This policy does not apply to any information collected by:
(a) us offline or through any other means, including on any other website or application operated by Company or any third party (including our affiliates or subsidiaries); and
(b) any third party, not otherwise requested by you, including through any application or content that may link to or be accessible from or in the Services.
(2) Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our Service. By accessing or using this Service, you agree to this Privacy Policy. This policy may change from time to time. Your continued use of this Service after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
(3) Our Service is not intended for children under 18 years of age. No one under age 18 may provide any information to the Website. We do not knowingly collect Personal Information from persons under 18. If you are under 18 and unless your consent is given or authorized by the holder of your parental responsibility in accordance with applicable law, do not use or provide any information on this Website or on or through any of its features, use any of the interactive or public comment features of this Service or provide any information about yourself to us. If a child under 16 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems.
2. Information we collect about you and how we collect it
(1) We may collect several types of information from and about users of our Service, including information:
(a) by which you may be personally identified, as outlined in the table below ("Personal Information");
(b) that is about you but individually does not identify you; and/or
(c) about your internet connection, the equipment you use to access our Service and usage details.
Personal Information - Examples of Personal Information include, but are not limited to:
Identity Information - Name, Address, marital status, date of birth, picture, signature, social security number or tax ID number, password, ID cards or similar.
Contact Information - Home address, email address, billing address, telephone number.
Online Presence Information - Social media websites, personal websites, and other online materials.
Financial Information - Bank account and payment card details, statements about your wealth and financial situation.Investment InformationInformation about your investment objectives, investment experience, prior investments.
Content Information - Any content you post to the Services.
Technical Information - Internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access this website or use our Services.
(2) We collect this information:
(a) directly from you when you provide it to us; and
(b) automatically as you navigate through the Website. Information collected automatically may include usage details, location, IP address, browser type and other information collected through cookies, web beacons, and other tracking technologies.
(3) We may also collect information provided by third parties, including, without limitation, websites, parties appointed by you, or other services that post our advertising materials. At times, our business partners, such as our affiliates and/or service providers collect personal information and share some or all of this information with us.
Information you Provide to us
(1) The information we collect on or through our Service may include:
(a) information that you provide by filling in forms on our Website, including information provided at the time of registering to use our Website or Service, requesting services or report a problem with our Service;
(b) records and copies of your correspondence (including email addresses and voice call details), if you contact us;
(c) details of transactions you carry out through our Website, as you may be required to provide financial information; and
(d) your response to surveys we may ask you to complete.
(2) We may also receive Personal Information that you provide when you place an order within our Services and the order is processed by another party, such as the payment processor. Such Personal Information may include billing and payment information.
4. Information we collect through Automatic data collection technologies
(1) As you navigate through and interact with our Service or with any of our advertising materials on third party services, we may use automatic data collection technologies to collect certain information about your equipment, interactions with the Services, and patterns, including, without limitation:
(a) details of your visits to our Website or Service, including traffic data, location data, and other communication data and the resources that you access and use on the Service; and
(b) information about your computer and internet connection.
(2) The information we collect through automatic data collection technologies may include Personal Information, or we may maintain it or associate it with Personal Information we collect or receive from third parties. It helps us to improve our Service, including by enabling us to estimate our audience size and usage patterns and store information about users’ preferences. For more information about this, please refer to our Cookie Policy.
(3) The technologies we use for this automatic data collection may include, without limitation:
(a) Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting you may be unable to access certain parts of our Website. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our Website.
(b) Web Beacons. Pages of our Website and our e-mails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit the Company, for example, to count users who have visited those pages or opened an email and for other related websites.
(c) Tracking Pixels. Certain features of our Services may use tracking pixels to allow Us to advertise more efficiently by excluding certain users from promotional content or delivering advertisements on other websites.
(d) Google Analytics and Other Similar Services. We may use Google Analytics and other similar services that use cookies to help us analyze how users interact with our Services and improve your experience in it.
5. Third-party use of cookies and other tracking technologies
(1) Some content or applications, including advertisements, on the Services are served by third-parties, including advertisers, ad networks and servers, content providers, and application providers. These third parties may use cookies or other tracking technologies to collect information about you when you use our Service. The information they collect may be associated with your Personal Information or they may collect information, including Personal Information, about your online activities over time and across different websites and other online services.
(2) Among content and applications served by third-parties, we may use, without limitation, the following services:Analytics - Google Analytics & Hotjar. Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network. You can opt-out of having made your activity on the Service available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js, and dc.js) from sharing information with Google Analytics about visits activity. For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: http://www.google.com/intl/en/policies/privacy/. We also use a service called Hotjar for similar purposes. For more information on their privacy practices, please visit https://www.hotjar.com/legal/policies/privacy/
(3) We do not control these third parties' tracking technologies or how they may be used. If you have any questions about an advertisement or other targeted content, you should contact the responsible provider directly.
6. How we use your information
(1) We use information that we collect about you or that you provide to us, including any Personal Information:
(a) to present our Service and its contents to you;
(b) to provide you with information, products, or services that you request from us;
(c) to fulfill any other purpose for which you provide it;
(d) to perform and develop services, deliveries, payments and products in connection with our Service;
(e) to carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing, collection, bookkeeping, support and marketing;
(f) to notify you about changes to our Website or any products or services we offer or provide through it;
(g) to develop our Services and provide better services, including by identifying and correcting technical issues;
(h) to deliver and target advertising;
(i) in any other way we may describe when you provide the information; and
(j) for any other purpose with your consent.
(2) We may also use your information to contact you about our own and third parties' goods and services that may be of interest to you. If you do not want us to use your information in this way, please contact us at the e-mail at the bottom of this Privacy Policy.
(3) We will keep your Personal Information in our possession for the period necessary for the fulfillment of our collection purposes, as provided in Section 6 (1) above.
7. Disclosure of your information
(1) We may disclose aggregated information about our users, and information that does not identify any individual, without restriction.
(2) We may disclose Personal Information that we collect or you provide as described in this Privacy Policy:
(a) to our subsidiaries, affiliates and related companies;
(b) to contractors, service providers, and other third parties we use to support our business, including, but not limited to firms for payment processing, developing, operations, sales, support, regulatory and tax filings, data analysis and marketing;
(c) to a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company's assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by Company about our customers and/or users is among the assets transferred;
(d) to fulfill the purpose for which you provide it;
(e) for any other purpose disclosed by us when you provide the information;
(f) to the SPV manager and/or organizer (which may be a natural person or legal entity), its affiliates or related companies or
(g) with your consent.
(3) We may also disclose your Personal Information:
(a) to comply with any court order, law, or legal process, including to respond to any legal duty, government or regulatory request;
(b) to enforce or apply any other agreements, including but not limited to for billing and collection purposes;
(c) if we believe disclosure is necessary or appropriate to protect the rights, property, or safety of the Company, our customers, or others, including but not limited to exchanging information with other companies and organizations for the purposes of fraud protection and credit risk reduction.
8. Choices about how we use and Disclose your information
(1) We strive to provide you with choices regarding the Personal Information you provide to us. We have created mechanisms to provide you with the following control over your information:
(a) Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, please note that some parts of this Service may then be inaccessible or not function properly.
(b) Promotional Offers from the Company. If you do not wish to have your contact information used by the Company to promote our own or third parties' products or services, you can opt-out by sending us an email stating your request to the email provided at the bottom of this policy.
(2) We do not control third parties' collection or use of your information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way.
9. Your privacy right
(1) Certain jurisdictions may permit certain users of our Service to withdraw its consent to this Privacy Policy. To make such a request, please send an email to the e-mail address at the bottom of this Privacy Policy. Please note that by withdrawing your consent to this Privacy Policy you will not be able to use the Website or use our Services. We will process such request in accordance with the applicable law.
(2) You may send us an email at the e-mail address at the bottom of this Privacy Policy to request access to, object, correct or delete any Personal Information that you have provided to us, as well as obtain restriction of processing in the cases provided by the applicable law. However, we reserve the right to not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
(3) In case of any inobservance with our legal requirements and duties, you have the right to file a complaint with the applicable data protection authority.
10. Data Security
(1) The safety and security of your information also depends on you. When we have given you a password for access to certain parts of our Website, you are responsible for keeping this password confidential. We require you not to share your password and login details with anyone.
(2) The Company takes the security of your data seriously. Payment Information is generally protected through the use of PCI-DSS-compliant third-party payment processors. For the handling of personal data, we aim at protecting your Personal Information through the use of SSL encryption. Unfortunately, the transmission of information via the internet is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted to our Services. Unless otherwise provided in the applicable legislation, any transmission of Personal Information is at your own risk.
11. Transfer to other countries
European Union citizens and others understand and agree that the Personal Information collected may be transferred to third countries, as some third parties, affiliates and subsidiaries supporting our business may be located in these countries. Your Personal Information may therefore be subject to privacy laws that are different from those in your country of residence. Please note that some countries may not offer the same type of protection and privacy for Personal Information provided. If you are located outside of the United States, please note you are agreeing that we transfer the data, including Personal Information, to the United States and process it there.
12. Notice to Europe union residents
Legal Basis for Processing Personal Data under the General Data Protection Regulation (GDPR)(1) We may process your Personal Information because:
(a) we need to perform a contract with you;
(b) you have given us permission to do so under the terms of this Privacy Policy;
(c) the processing is in our legitimate interest and it is not overridden by your rights;
(d) we may need to collect or process payment in exchange for the Services; and
(e) we need to comply with applicable laws.Your Data Protection Rights under the General Data Protection Regulation (GDPR)
(2) We strive to comply with all applicable laws relating to our collection and processing of your Personal Information. In certain circumstances and as provided under applicable law, you have the following data protection rights:
(a) the right to access, update or delete the information we have on you;
(b) the right to rectify any information that is inaccurate or incomplete;
(c) the right to object to any unlawful processing of your Personal Information;
(d) the right to request the restriction of our processing of your Personal Information;
(e) the right to know and receive a copy of the information we may have on you; and
(f) the right to withdraw your consent at any time where we relied on your consent to process your Personal Information.
(3) For any requests relating to your rights under the GDPR, please notify us at the email address at the bottom of this page. Furthermore, you have the right to complain to a Data Protection Authority about our collection and use of your Personal Information.
13. Privacy policies of Linked sites and Apps
Our Services may contain links to third-party websites or applications. We are not responsible for the privacy practices or the content of such third parties. Please note that, once you leave our Service or Website, third parties’ privacy policies will apply to any information collected. If you have any questions about how these other websites or applications use your information, you should review their policies and contact them directly. This Privacy Policy applies solely to information collected by us or otherwise stored by us.
14. Changes to our privacy policy
It is our practice to post any changes we make to our Privacy Policy on this page. If we make material changes to how we treat our users' Personal Information, we will notify you by updating our Privacy Policy on the Website. You are responsible for periodically visiting our Website and this Privacy Policy to check for any changes.
15. Governing law and dispute resolution
This Privacy Policy and any dispute arising hereunder will be governed by the laws of the State of Florida and/or applicable federal laws of the United States of America without regard to its choice of law or conflicts of law principles. Both you and the Company agree that all claims and disputes arising out of or relating to this Privacy Policy will be litigated exclusively in the courts located in Miami, Florida.
16. Contact Information
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:
Allocations Fund Administration LLC By email: support@allocations.com
