Privacy policy.
Privacy Policy
Last Revised: June 16, 2021
Introduction
Defined Capital Management, LLC (“Defined Capital” or “We”) respect your privacy and is committed to protecting it through our compliance with this policy. This policy describes the types of information we may collect from you or that you may provide when you visit the website defined.capital (our “Website”) and our practices for collecting, using, maintaining, protecting and disclosing that information.
This policy applies to information we collect:
· On our Website
· In e-mail, text and other electronic messages between you and Defined Capital.
· When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.
· When you subscribe to an investment in our funds.
It does not apply to information collected by:
· Any third party including through any application or content (including advertising) that may link to or be accessible from or on the Website, because this content is out of our control.
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 Website. By accessing or using our Website, you agree to this privacy policy. This policy may change from time to time. Your continued use of our Website after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.
Children Under the Age of 18
Our Website is not intended for children under 18 years of age. No one under age 18 may provide any personal information to or on the Website. We do not knowingly collect personal information from children under 18. If you are under 18, do not use or provide any information on our Website or on or through any of its features/register on the Website, make any purchases through the Website, use any of the interactive or public comment features of our Website, or provide any information about yourself to us, including your name, address, telephone number, e-mail address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 18, please contact us at team@defined.capital.
Information We Collect About You and How We Collect It
We may collect several types of information from and about users of our Website, including information:
by which you may be personally identified, such as name, postal address, e-mail address, telephone number, social security number, passport number, date of birth, taxpayer or government identification number, or any other identifier by which you may be contacted online or offline (“personal information”);
that is about you but individually does not identify you, such as gender, salary, and job; and/or
about your internet connection, the equipment you use to access our Website and usage details.
We collect this information:
Directly from you when you provide it to us.
Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, device information including, but not limited to, identifier, device name and type, operating system, location, mobile network information, and standard web log information, such as your browser type, traffic to and from our site, and the pages you accessed on our website, and information collected through cookies, web beacons, and other tracking technologies.
From third parties; for example, credit bureaus, identity verification services, and our business partners.
Information You Provide to Us
The information we collect on or through our Website may include:
Information that you provide by filling in forms on our Website.
Information received from you on subscription documents and other forms (for example, name, address, social security number, telephone and fax numbers, assets and income);
Records and copies of your correspondence (including e-mail addresses), if you contact us.
Your responses to surveys that we might ask you to complete for research purposes.
Details of transactions you carry out through our Website and of the fulfillment of your orders. You will be required to provide financial information before placing an order through our Website.
Confidentiality and Security
The security of your information is our priority. We protect this Information by maintaining physical, electronic and procedural safeguards that comply with applicable laws and federal regulations.
Disclosure of Information
We do not disclose information about our clients or former clients except as required by law, including disclosures made with your consent or as necessary to process and service your account, to protect against fraud, or to protect the security or confidentiality of our records. In addition, we may disclose Information to affiliated and non-affiliated third parties that provide services necessary to effect a transaction that you request or to service your account, such as prime brokers, accountants, auditors, banks, attorneys or administrators. Finally, we may be required to disclose Information to government agencies, courts, parties to lawsuits or regulators in response to subpoenas; in such cases, we share only the information that we are required or authorized to share. Except in those specific, limited situations, we will not make any disclosures of Information to other companies without your consent.
Information We Collect Through Automatic Data Collection TechnologiesAs you navigate through and interact with our Website, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions and patterns, including:
Details of your visits to our Website, including traffic data, location data, logs and other communication data, and the resources that you access and use on the Website.
Information about your computer and internet connection, including your IP address, operating system, and browser type.
We do not track our user over time and across third-party websites to provide targeted advertising and therefore does not respond to Do Not Track (DNT) signals. Third parties that have content embedded on our websites may set cookies on a user’s browser and/or obtain information about the fact that a web browser visited a specific our website from a certain IP address.
See your web browser’s documentation for information on how to enable DNT signals and learn about other mechanisms that enable consumers to exercise choice about behavioral tracking.
The information we collect automatically is statistical data and may include personal information, but we may maintain it or associate it with personal information we collect in other ways or receive from third parties. It helps us to improve our Website and to deliver a better and more personalized service, including by enabling us to:
Estimate our audience size and usage patterns.
Store information about your preferences, allowing us to customize our Website according to your individual interests.
Speed up your searches.
Recognize you when you return to our Website.
The technologies we use for this automatic data collection may include:
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.
Flash Cookies. Certain features of our Website may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our Website. Flash cookies are not managed by the same browser settings as are used for browser cookies.
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 e-mail and for other related website statistics (for example, recording the popularity of certain website content and verifying system and server integrity).
Third-party Use of Cookies and Other Tracking Technologies
Some content or applications on the Website are served by third-parties, including content providers and application providers. These third-parties may use cookies alone or in conjunction with web beacons or other tracking technologies to collect information about you when you use our website. 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. They may use this information to provide you with targeted content.
We do not control these third-parties’ tracking technologies or how they may be used. If you have any questions about targeted content, you should contact the responsible provider directly.
How We Use Your Information
We use information that we collect about you or that you provide to us, including any personal information:
To present our Website and its contents to you.
To provide you with information, products, or services that you request from us.
To fulfill any other purpose for which you provide it.
Resolve disputes, collect fees, and troubleshoot problems.
To notify you about changes to our Website or any products or services we offer or provide though it.
To allow you to participate in interactive features on our Website.
In any other way we may describe when you provide the information.
For any other purpose with your consent.
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 check the relevant box located on the form on which we collect your data (the registration form) or adjust your user preferences in your account profile.
Your California Privacy Rights
California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to team@defined.capital.
Changes to Our Privacy Policy
It is our policy to post any changes we make to our privacy policy on this page with a notice that the privacy policy has been updated on the Website home page. If we make material changes to how we treat our users’ personal information, we will notify you by e-mail to the primary e-mail address specified in your account or through a notice on the Website home page. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable e-mail address for you, and for periodically visiting our Website and this privacy policy to check for any changes.