How to Use this Privacy Policy
This policy describes if and how your Personal Information is shared and/or disclosed, how we collect and use other information and how we address other privacy matters – such as deletion of your Personal Information upon request, and opting-out of marketing communications. Lastly, we describe methods for contacting Avestor if you have privacy questions, comments or feedback.
Transparency is one of the best ways to earn your trust. The information we collect from you increases as your relationship with us grows. The progression of that relationship is shown in the figure below. Additional information of what we collect is presented in the How We Collect & Use Your Information section of this privacy policy.
How We Collect & Use Your Information
“Personal Information” means your personally-identifiable information such as your name, email or mailing address, phone number, account credentials (user id and passwords), social security number, government ID numbers and other information that can be used to identify you personally.
We also collect and use other information that we obtain from your activities using our services. This includes information that you do not explicitly provide to us but which may be implicitly provided to us as part of such activities. More information on this is provided below.The following describes in further detail the information we collect at various stages of our relationship with you:
Individuals who visit our public website without logging into an account.
Users that establish an online account with us or one of the Sponsors with an investor portal on our platform.
Registered users that invest capital through any of the funds or Sponsor funds on our platform.
Internet protocol (IP) address, Your cookie information, Where do you visit us from, Your browser information
Your first & last name, Your email address, Your password (encrypted) are required. Uses can optionally add additional Client information as as they initiate the process to become a Client.
Detailed personal information including but not limited to permanent address, phone, photo ID, social security number, accreditation status, etc. We also run automated Know Your Customer (KYC) and Anti-money Laundering Checks (AML) on each Client on our platform.
To understand who is interested in our platform, Where they are coming from, Monitoring usage to improve our site, For security analyses of our site, Assess effectiveness of any marketing campaigns
To have necessary information to contact you about our services, To allow you to review more detailed information to determine if you want to become a client, To enable multi-factor authentication, For security analyses of our site
To meet US legal and regulatory requirements. To enable personalized service.
The below table explains what we are collecting and if it can be limited.
Internet protocol (IP) address
No. The only way to avoid this is not visiting our sites.
Yes. Most modern browsers allow you to delete or limit cookies. Deleting these cookies will impact your experience with our website and services.
Third-party tags & cookies
Yes. Most modern browsers allow you to delete or limit cookies, including third-party cookies however you may not be able to limit marketing tags entirely unless you do not visit our sites.
No, that is required to have a functioning account. You can opt out of marketing emails, see the Opt-Out section.
Your email address & password
No, that is required to have a functioning account. You can opt out of marketing emails, see the Opt-Out section. It is required to enable multi-factor authentication.
Detailed personal information including legal name, address, phone numbers, social security, driver’s license, and other financial information.
No. We require this information to establish your Client account. Information such as driver’s license is required by law to establish your identify. Your address and social security number are required to send you and the IRS your tax related information. KYC/AML checks are required to meet US anti-money laundering rules. Finally, your status as accredited investor is collect to meet SEC regulations.
What User information do we share & with whom?
The below table outlines what information we may share and why with our partners.
As most businesses, we may use third-party service providers to deliver the services to us such as KYC (know your customer), electronic signature, bank account connections, tax and accounting services. In doing so, we may provide some of your personal data to those third-party service providers. Those service providers are required under contract or fiduciary responsibility to safeguard your information either directly through Avestor or through one of our Sponsors. Except where expressly set forth in this policy, our third-party service providers may only use your data for the sole purpose of providing a service to us or our Sponsors.
We may share users emails (or email hashes) and names in some cases with partners or partner platforms to enable marketing our services to you. We do not sell or allow your information to be used for any purpose.
If you fill out a form on our website requesting a Sponsor to contact you, we will provide that information to the Sponsor. We also maintain a record of your personal information in our database and may contact you for future products and/or services.
Security, Legal & Regulatory Requirements
We reserve the right to disclose information about you that we believe, in good faith, is appropriate or necessary to (i) take precautions against liability, (ii) protect ourselves or others from fraudulent, abusive, or unlawful uses or activity, (iii) investigate and defend ourselves against any third-party claims or allegations, (iv) protect the security or integrity of the Service and any facilities or equipment used to make the Service available, (v) if mandated by law or regulatory requirement, or (vi) protect our property or other legal rights (including, but not limited to, enforcement of our agreements), or the rights, property, or safety of others.
California
California Consumer Privacy Act Privacy Statement (“CCPA Statement”)
This CCPA Statement is provided pursuant to the California Consumer Privacy Act (“CCPA”) and applies to California residents and supplements our overall Statement with additional disclosures and rights.
Your rights under CCPA
As of January 1, 2020, California law permits residents of California to request certain details about how their personal information is shared with third-parties or affiliated companies for direct marketing purposes.
California residents may also take advantage of the following rights:
You may request, up to two times each year, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, any categories of personal information about you that we sold, the categories of third-parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable.
You may request that we delete any personal information that we have collected from or about you. As described in more detail in our Statement, there are some reasons we will not be able to fully address your deletion request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation.
To take advantage of your disclosure and deletion rights, please contact us at aupport@avestorinc.com. We may need to verify your identity to enable us to process your request. We value your privacy and will not discriminate in response to your exercise of privacy rights. We will respond to your request within 45 days of receipt of your request, after proper verification, unless we need additional time, in which case we will let you know.
Links to Other Web Sites
This Privacy Policy applies only to Avestor. Our Site or Services may contain links to other web sites not operated or controlled by us. The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Company endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.
Additional Privacy Information
How to Request Deletion of the Personal Information We Collect
Avestor allows you to delete your registered account if you are not a client. If you are a client or were previously a client, we must maintain your account to deliver required statements and tax related information to you. To delete your account, please email us at support@avestorinc.com.
Opt-out Information
If you request to be added to our Opt-out lists, we will keep your Personal Information on those Opt-out lists until you request to be removed from such lists. We allow you to Opt-out of the following:
Marketing emails – send your request to support@avestorinc.com to be added to the opt-out list.
Physical Mailings - send your request to support@avestorinc.com to be added to the opt-out list.
Advisory phone calls - notify your advisor at the time of the call that you prefer no proactive phone calls and will reach out to Avestor when required.
If you request to be added to our Opt-out lists, we will keep your Personal Information on those Opt-out lists until you request to be removed from such lists. We allow you to Opt-out of the following:
- Marketing emails – send your request to support@avestorinc.com to be added to the opt-out list.
- Physical Mailings - send your request to support@avestorinc.com to be added to the opt-out list.
- Advisory phone calls - notify your advisor at the time of the call that you prefer no proactive phone calls and will reach out to Avestor when required.
Email Records
Avestor keeps business records, including emails you send to us, for up to five (5) years after you close your account and all funds are distributed to you to meet our regulatory compliance requirements. This includes any email you send to our privacy, security or support teams.
Children and Minors
Avestor does not knowingly collect Personal Data from minors under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a minor under the age of 18 has provided Personal Data to Avestor through the Services, please contact us, and we will endeavor to delete that information from our databases.
Modifications to our Privacy Policy
Our business may change from time to time. As a result, at times it may be necessary for Avestor to make changes to our Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.
Privacy Questions, Comments or Feedback?
Please contact us at support@avestorinc.com
