Privacy Policy - AltsAxis

This Privacy Policy Notice (“Notice”) is a public document from AltsAxis, LLC (“AltsAxis” or “we,” “us,” and “our”) posted at https://AltsAxis.com/Privacy-Policy/ that explains how AltsAxis processes personal data and how AltsAxis applies data protection principles. AltsAxis, LLC, is a limited liability company formed in the State of Delaware, in the United States of America (“U.S.”). AltsAxis operates in the U.S. the website www.AltsAxis.com (the “website”) as an information outlet accessible to targeted audiences worldwide to share information that we find useful to qualified purchasers, investment managers, institutional investors, and similar participants in the investment industry.

We have implemented the following Privacy Policy (“Policy”) with respect to how we manage and safeguard the data that we collect, including via our website, in which the data may include nonpublic confidential information, personal information, and personally-identifiable information (“PII”) (“personal data”). We strive to comply with the ever-changing landscape of laws and regulations regarding data privacy, data protection, and data breach notification, such as various State and Federal privacy and data laws across the U.S., the General Data Protection Regulation (GDPR) requirements across the EU, and other third-country-specific requirements. This Notice and the Policy will be updated as this landscape or the application thereof to us changes. This Notice explains, among other topics: (1) what personal data may be collected regarding you (“you” and “your”) as a person using the website (a “user”); (2) the purposes for which your data may be used; (3) the third parties to whom your personal data may be disclosed; and (4) how you may exercise your rights in relation to your personal data.

Data collected on the basis of legitimate interest

Based on our legitimate interests, we collect the herein-mentioned data for the herein-mentioned purposes in conjunction with running this website and our business. Our legitimate business interests and purposes of our processing of your data include our activities of researching the current and historical trends in the financing, performance, and investment metrics in the alternative asset industry, and providing data and information on the persons and the firms active in this industry. These activities include the provision of company and business professional contact information such as name, role, business address, phone number, and email address. Such information may be displayed in our products.

Data collected on the basis of your consent

By using our website, you consent to our Privacy Policy. By using our website, you agree to and provide consent to our collection in the U.S. and herein-mentioned uses of your personal data.

Upon your request and expression of consent, we collect your personal data for the purposes mentioned herein. Your data are not used for any other purposes or shared with third parties apart from disclosed herein. Subject to limitations and conditions, your data may be removed upon your withdrawal of consent or your request to terminate theses services.

What data do we collect?

We collect the following data:

Personal identification information (e.g., name, email address, phone number, mailing address, organization, role, age confirmation, etc.)
IP address, device ID, browser ID, and browser user agent string
Website session information, including page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page.
Website technical information to help us identify your device for fraud prevention and diagnostic purposes.
Any in-person visits to our offices may be captured and recorded in one or more audio-visual surveillance video recordings.

How do we collect your data?

You directly provide us with much of the data we collect. We collect data and process data when you:

Register online or place an order for any of our products or services.
Voluntarily complete a customer survey or provide feedback on any of our message boards or via email.
Use or view our website via your browser’s cookies.

We may also receive your data indirectly from the following sources:

Public sources and publicly-available websites (e.g., SEC filings, including Form 13F and Form ADV filings, etc.)
Submission, contribution, and/or mention by other users or sources
Mobile app: when you download or use our app, we may receive information about your location and your mobile device, including a unique identifier for your device. Most mobile devices allow you to turn off location services. For more information about how to do this, please contact your mobile service carrier or your device manufacturer.
E-mail Communications: when you open e-mail from us, or download images linked in an email from us, we may receive a confirmation of such activity, if your computer supports such capabilities. If you do not want to receive e-mail or other mail from us, please unsubscribe from our emails, do not open our emails, do not download images in our emails, or otherwise notify us.

We may collect personally identifiable information about you when you choose to register on the website or to place an order with us. We also obtain relevant information from direct interactions or publicly available sources such as company corporate websites, LinkedIn profiles, regulatory filings, and news alerts. If you register for or attend an event organized by us, we will have collected your name, firm name, business address, and other contact details. Event attendee data also may be collected where we co-sponsor an event. We also may obtain your mobile phone number, social media ID, and/or messaging ID from direct interactions with you.

The personal data may include, but are not limited to, name, e-mail address, mailing address, phone number, age confirmation, role, and organization name from information provided by you or your employer through our registration process and subsequently through other means such as, but not limited to, your use of the website (such as via website cookies), survey forms, or optional contact forms. We may monitor your conduct on the website for any lawful reason or purpose. We may collect and process personal data relating to you in connection with our on-going relationship with you or your company, such as via correspondence and calls. You may, however, visit many areas of our website anonymously by having your browser settings set to block the website’s cookies.

How will we use your data?

Personal data that you provide, or your company provides, on the website, or that we otherwise may obtain in relation to you, will be processed to complete your specific profile (“user profile”) in our databases. Any of the information we may collect from you may be used in one or more of the following ways, without limitation, mentioned below.

We collect your data so that we can:

Process your order(s) and manage your account.
Email you with special offers on other products and services we think you might like.
Create, update, manage, and/or process your user profile.
Service and/or administer your user experience (e.g., your information may help us to better respond to your individual needs).
Improve customer service (e.g., your information may help us to effectively respond to your customer service requests and support needs).
Process transactions relating to and/or involving you.
Maintain appropriate business records.
Conduct statistical analysis and/or market research based on user profiles and interaction with the website.
Respond to and/or evaluate any queries or complaints relating to and/or involving you.
Establish, exercise, and/or defend legal claims relating to and/or involving you.
Conduct direct marketing and related purposes, subject to any preferences you may communicate to us.
Improve, optimize, and/or develop our website and/or products.
Leverage surveillance videos, including audio clips and still images, which may be used in routine administration of our offices, as well as in the process of crime prevention, crime detection, and crime investigations.
Leverage mobile app data to provide you with location-based services, such as advertising, search results, and other personalized content, and to compile statistics regarding app activity.
Leverage email data to help us make e-mails more useful and interesting to you, and to compile statistics regarding email activity.

If you agree, we will share your data with our partner companies so that they may offer you their products and services.

The process of identifying partner companies presently is in its initial stage, and this Notice will be updated as partner companies are identified.

When we process an order for you, we may send your data to, and also use the resulting information from, credit reference agencies and/or other service providers to prevent fraudulent purchases.

The aforementioned uses of your personal data may involve your personal data being exchanged, transferred, or given to another company (e.g., an Internet service provider (“ISP”) or a software-as-a-service (“SaaS”) provider) for the reason and purpose of implementing, providing, and/or facilitating the aforementioned uses. Your personal data will not be exchanged, transferred, or given to any other company for any reason whatsoever, without your consent, other than for the express purpose of delivering the purchased product or service requested. Your personal data will not be sold without your consent.

How do we store your data?

We securely store your data at server centers within the Amazon Web Services (“AWS”) network. We store and process your data using cloud hosting providers in the U.S.

We will keep your personal data for an indefinite period of time, but at least as long as may be required, such as for tax purposes relating to transactions involving you, e.g., seven years after the tax year in question. Once this time period has expired, we expect to delete your data by an automated archival and deletion process expected to occur on a monthly basis, absent any intervening change in circumstances or law that would require a different outcome.

International transfers of personal data

We are based in the U.S. and use an ISP in the U.S. to host our website and collect your personal data. Users worldwide may access the website and create user profiles. If you are a user outside of the U.S., you consent to any transfer to, collection in, and transfer from the U.S. of your personal data (e.g., during your access of and bi-directional interaction with the website). In connection with the aforementioned purposes, we may transfer your personal data outside the U.S. and outside the country in which you accessed the website (“access country”) and provided your personal data. For instance, a SaaS software application may be provided and/or hosted in a third country by a data processor.

Such data movement may include moving personal data collected from a user in an access country within the European Economic Area (“EEA”) and/or the European Union (“EU”) to a third country outside the EEA, including to a jurisdiction that is not recognized by the European Commission as providing for an equivalent level of protection for personal data as is provided for in the EEA or EU. At present, the EEA includes all 27 EU members states, plus Iceland, Liechtenstein, and Norway, forming together the single European internal market of EU/EEA area. The United Kingdom (UK) was an EU/EEA member state until December 31, 2020, when the UK left the EU and EEA. Switzerland is neither an EU member nor EEA member. (See https://www.efta.int/eea).

If and to the extent that we transfer your personal data as a user (a “data subject” under the GDPR means a citizen or resident of the EU) from an EEA/EU access country to a non-EEA/EU country, we will ensure that appropriate measures are in place to comply with our obligations under applicable law governing such transfers, and such measures may include: (a) entering into a contract governing the transfer, in which the contract contains the “standard contractual clauses” approved for this purpose by the European Commission; (b) in respect of transfers to the United States of America, ensuring that the transfer is covered by the EU-US Privacy Shield framework; or (c) transferring your personal data pursuant to binding corporate rules.

Marketing uses of personal data

We would like to send you information about products and services of ours that we think you might like, as well as those of our partner companies.

The process of identifying partner companies presently is in its initial stage, and this Notice will be updated as partner companies are identified.

If you agree or have agreed to receive marketing, you may always opt out at a later date.

Opt‐Out provisions

You have the right at any time to stop us from contacting you for marketing purposes or giving your data to other members of our Company Group.

If you no longer wish to be contacted for marketing purposes, please an email to Opt-Out@AltsAxis.com.

You may limit us or our affiliates from marketing their products or services to you based on the information that we collect and share with them. Your choice to limit marketing offers will apply until you tell us to change your choice. If you have already made a choice to limit marketing offers from our affiliates, you do not need to act again until you receive the renewal notice.

To limit marketing offers, contact us by mail at the address below or by sending an email to Opt-Out@AltsAxis.com.

Statistics regarding website usage

The website uses Google Analytics, a service which transmits website traffic data to Google servers in the United States and allows us to notice trends to improve the user experience on our website. This service processes personal data such as: the unique User ID set by Google Analytics, the date and time, the title of the page being viewed, the URL of the page being viewed, the URL of the page that was viewed prior to the current page, the screen resolution, the time in local time zone, the files that were clicked on and downloaded, the links clicked on to an outside domain, the type of device, and the country, region, and city.

You may opt out of this tracking at any time by activating the “Do Not Track” setting in your browser.

How do we protect your information?

We implement a variety of security measures to maintain the safety of your personal information when you place an order.

We offer the use of a secure server. All supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted into our payment gateway provider’s database only to be accessible by those authorized with special access rights to such systems and are required to keep the information confidential.

After a transaction payment by credit card, your private credit card information will not be stored on our servers.

What are your data protection rights?

We would like to make sure you are fully aware of all of your data protection rights. You have the following rights, in certain circumstances and subject to applicable exemptions, in relation to your personal data. Every user is entitled to the following:

The right to access, right to know –

You have the right to access the personal data that we hold about you, together with other information about our processing of that personal data. You have the right to request that we provide to you copies of your personal data. We may charge you a small fee for this service.

The right to rectification –

You have the right to request that we rectify any inaccuracies in your personal data and correct any information that you believe is inaccurate. You also have the right to request that we complete the information that you believe is incomplete.

The right to erasure, right to be forgotten –

You have the right to request that we erase your personal data, under certain conditions. If you do not want to receive e-mail or other mail from us, please unsubscribe from our email, change your communication preferences in your account configuration page, or otherwise notify us.

The right to restrict processing, right to opt out of sharing with third parties –

You have the right to request that we restrict the processing of your personal data, under certain conditions. You have the right to request that we no longer process your personal data for particular purposes.

The right to object to processing –

You have the right to object to our processing of your personal data, under certain conditions. You have the right to object to our use of your personal data or the way in which we process it, under certain conditions.

The right to data portability –

You have the right to request that we transfer the data that we have collected to another organization, or directly to you, under certain conditions. Where the legal basis for processing is that it is necessary for the performance of a contract with you, you have the right to receive your personal data, which you provided to us, in a structured, commonly-used, and machine-readable format or to require us to transmit that data to another controller.

The right to be free from discrimination –

You have the right to be free from discrimination in the use and processing of your personal data, and to receive equal service and pricing us, even if you exercise your privacy rights under the CCPA.

If you make a data privacy request, we have one month to respond to you. If you would like to exercise any of these rights, please contact us using the contact information provided below, preferably at our email address:

Email us at: DataPrivacyRequest@AltsAxis.com

Call us at: +1 (908) 777-1550

Or write to us: AltsAxis, LLC
100 Connell Drive, Suite 2300
Berkeley Heights, NJ 07922
USA

Cookie Policy:

Cookies from our website

Cookies are text files placed on your computer to collect standard Internet log information and visitor behavior information. When you visit our website, we may collect information from you automatically through cookies or similar technology.

For further information about cookies, visit www.allaboutcookies.org.

Do we use cookies?

Yes. If permitted by your browser, our website or its service provider may transfer small cookie files to your computer’s hard drive through your web browser (if you allow) that enables the website or service provider’s system to recognize your browser and capture and remember certain information.

How do we use cookies?

We use cookies to understand and save your preferences for future visits and compile aggregate data about website traffic and website interaction, so that we can offer better website experiences and tools in the future.

We use cookies in a range of ways to improve your experience on our website, including:

Keeping you signed in
Understanding how you use our website
Supporting website traffic analytics, statistics, and stability efforts (e.g., detecting and undermining attempts to effectuate a Denial Of Service (“DOS”) or a Distributed Denial Of Service (“DDOS”))

What types of cookies do we use?

There are several different types of cookies that our website uses, including:

Functionality – We use these cookies so that we recognize you, your browser, or your device, when accessing our website, and remember your previously-selected preferences. These cookies might include data indicating, for instance, what language you prefer and where you are located. Various combinations of first-party and third-party cookies are used, depending on permissions set in your browser settings.
Advertising – We use these cookies to collect information about your visit to our website, the content you viewed, the links you followed, and information about your browser, device, and your IP address. We sometimes share some limited aspects of these data with third parties for advertising purposes. We also may share online data collected through cookies with our advertising partners. This sharing means that when you visit another website, you may be shown advertising based on your browsing patterns on our website.

How to manage cookies

You can set your browser not to accept some or all cookies, and the website www.allaboutcookies.org tells you how to remove cookies from your browser. However, in a few cases, some of our website features may not function as a result.

Privacy policies of other websites

Our website contains links to other websites. Our Privacy Policy and this Notice apply only to our website, so if you click on a link to another website, you should read that other website’s privacy policy.

Links to third-party websites

Occasionally, at our discretion, we may include or offer third-party products or services on our website. These third-party websites also have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked websites. Nonetheless, we seek to protect the integrity of our website, and we welcome any feedback about these third-party websites.

Embedded content from other websites

Articles on the website may include embedded content (e.g., videos, charts, etc.). Embedded content from other websites preferably behaves (subject to your browser settings) in the exact same way as if you had visited the other website.

These websites may collect data about you, use cookies, embed additional third-party tracking, and monitor your interaction with that embedded content, including tracking your interaction with the embedded content if you have an account and are logged in to that website.

Confidentiality and security

While we have endeavored to create a secure and reliable website for you and our users, we cannot ensure or warrant the security or confidentiality of any information you and users transmit to and from the website. Unfortunately, no data transmission over wireless and wired networks is entirely or inherently secure. When disclosing any personal data, you should remain mindful that the information is potentially accessible to the public, and consequently, might be collected and used by others without your knowledge or consent.

We will use all reasonable efforts to safeguard the privacy of your personal data disclosed to us; however, subject to any statutory limitations, we assume no liability for disclosure of data due to errors in transmission or acts by unauthorized outside parties.

We work to protect the security of your information during transmission by using Secure Sockets Layer (SSL) software, which encrypts information you input.

We reveal only the last four digits of your credit card numbers when confirming an order. Of course, the website transmits the entire credit card number to the appropriate credit card company during order processing, but this information is protected by SSL encryption.

If you have an account and sign into your account, it is important for you to protect against unauthorized access to your password and to your computer. Be sure to sign off when finished using a shared computer.

You can help ensure that your contact information and preferences are accurate, complete, and up to date by logging into Your Account. For other personal information we hold, we will provide you with access for any purpose, including to request that we correct the data or delete the data, if we are not required to retain it by law or for legitimate business purposes. We may decline to process requests that are frivolous, are vexatious, jeopardize the privacy of others, are extremely impractical, or for which access is not otherwise required by local law. Access, correction, or deletion requests can be made by contacting us at the email below.

Do we disclose any information to outside parties?

We do not sell or trade to third parties your personally identifiable information. The aforementioned uses determine whether we transfer to outside parties your personally identifiable information. The restriction on transfers of personal data to third parties does not apply to or include transfers to trusted service providers who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. and preferably agree to a GDPR-compliant data processing agreement. We may also release your information when we believe release is appropriate to comply with the law, enforce our website policies, or protect our or others’ rights, property, or safety. However, non-personally identifiable visitor information may be provided to other third parties for marketing, advertising, or other uses.

Compliance with the California Data Privacy Laws

The California data privacy laws include, e.g., the California Online Privacy Protection Act, the California Consumer Privacy Act, and the California Privacy Rights Act.

We value the privacy of our users in California covered by the California Online Privacy Protection Act (“COPPA”) of 2003, the California Consumer Privacy Act (“CCPA”) of 2018, and the California Privacy Rights Act (“CPRA”) of 2020, which launches January 1, 2023, in addition to the California Shine The Light Law, the California Information Security Statute, the California Disposal of Consumer Records law, and the California Data Breach Notification Statute. We strive to be in compliance with the developing requirements of the COPPA, the CCPA, and the CPRA. We therefore will not sell your personal information to third parties without your consent. Please use the link titled “Do Not Sell My Personal Information” for more information.

Pursuant to the California Online Privacy Protection Act, as a user of our website, you may make any changes to your information at any time by logging into your control panel and going to the ‘Edit Your Profile’ page.

Compliance with the U.S. Federal Children’s Online Privacy Protection Act

We are in compliance with the requirements of the U.S. Children’s Online Privacy Protection Act (U.S. “COPPA”) of 1998 under U.S. federal law. We do not knowingly or intentionally collect any information from anyone under 13 years of age. In using our website, you are permitted to submit personal data only in conjunction with confirming that you are over 13 years of age. Moreover, our website, products, and services are all directed to people who are at least 18 years old or older. A user must be at least 18 years old to create an account with our website and app.

Changes to our Privacy Policy

We keep our Privacy Policy under regular review and place any updates to this Notice and the Policy on this web page.

This Privacy Policy was last updated on 14 January 2022.

This Notice was last modified on 14 January 2022.

If you have any concern about privacy at our website, please contact us with a thorough description, and we will try to resolve it. Our business changes constantly, and our Privacy Policy and this Notice will change also. We may e-mail periodic reminders of our changes, but you should check our website frequently to see recent changes. Unless stated otherwise, our current Privacy Policy Notice applies to all information that we have about you and your account.

We may revise this Privacy Policy Notice from time to time. The most current posted version of the policy will govern our use of your information and will always be found at https://AltsAxis.com/Privacy-Policy/. If we make a change to this Policy that, in our sole discretion, is material, we will notify you via email to the email address associated with your account. By continuing to access or use the services at our website after those changes become effective, you agree to be bound by the Policy and Notice as revised.

How to contact us

If you have any questions about our Privacy Policy, the data we hold regarding you, or you would like to exercise one of your data protection rights, please do not hesitate to contact us.

Our company representative is: David Weinberg, Esq., Business & Legal Affairs; Legal@AltsAxis.com.

Our EU representative for the GDPR is presently unidentified, as the requirement for an EU representative presently is not applicable to us, pursuant to the terms of Art. 27(2)(a) at https://gdpr.eu/article-27-representatives-of-controllers-not-in-union/.

Our Data Protection Officer is: Kevin Curran, Esq., DPO@AltsAxis.com.

Email us at: DataPrivacyRequest@AltsAxis.com

Call us at: +1 (908) 777-1550

Or write to us: AltsAxis, LLC
100 Connell Drive, Suite 2300
Berkeley Heights, NJ 07922
USA

How to request that we erase your personal data

To request that we erase your personal data from our platform, please complete the form, and mail to us the form and the evidence required in the form, that is available for downloading here: https://gdpr.eu/wp-content/uploads/2019/01/RIGHT-TO-ERASURE-REQUEST-FORM.pdf

How to contact the appropriate authority

Should you wish to report a complaint or if you feel that we have not addressed your concern in a satisfactory manner, you may contact the appropriate authority at a relevant Information Commissioner’s Office.

For GDPR, to see the contact details for the various countries’ GDPR Supervisory Authorities, visit https://edpb.europa.eu/about-edpb/about-edpb/members_en
including:

European Data Protection Supervisor
Rue Wiertz 60
Office: Rue Montoyer 30, 6th floor
1047 Bruxelles – Brussel
Tel. +32 2 283 19 00
Fax +32 2 283 19 50
Email: edps@edps.europa.eu
Website: https://edps.europa.eu/

For U.S. COPPA, visit https://www.ftc.gov/contact, or contact:

Bureau of Consumer Protection
Federal Trade Commission
600 Pennsylvania Avenue, NW
Washington, DC 20580
Telephone: (202) 326-2222

(End of Notice)