1. EFFECTIVE September 1, 2020
The privacy practices of this Privacy Policy apply to our services available under the domain and subdomains of www.crosslinkcapital.com (the “Site”). We recognize that privacy is important to our users, so we have adopted policies with the protection of your privacy in mind. This Privacy Policy outlines the types of personal information we may gather when you visit our Site or use our services, as well as some of the policies that we have adopted to safeguard your privacy. Please read this Privacy Policy to learn more about the policies that we have adopted regarding the protection, use and disclosure of your personal information. By visiting the Site, you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree, please do not use or access the Site. By accepting the Privacy Policy and the Terms of Use, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the terms of the Terms of Use.
2. OVERVIEW
We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information that we obtain from our clients and investors in our funds, and the information we gather over the Site is protected by those policies and procedures. Generally, we collect non-public personal information about our clients and investors from the following sources:
- Information a client or investor gives us on applications or other written communication and during telephone and in person meetings when the client applies to open an account or receive investment advice or provides a subscription document in connection with a fund investment (which information may consist of the client’s or investor’s identification and contact information, age, occupation, home address, email address, telephone number, financial information and goals, asset, income and expense profiles, risk tolerance, tax identification numbers, and such additional financial information as we need to provide our services to such client or investor); and
- Information generated by a client’s or an investor’s other service providers, such as brokerage and custodians, to service client or investor accounts (such as trade tickets, account statements, tax information reports, trade confirmations, confirmations of contributions and withdrawals and similar account information)
Our policy is that:
* We do not disclose any non-public personal information about our clients or investors or former clients or investors to anyone, except as permitted by law. We may voluntarily disclose non-public personal information about our clients or investors or former clients or investors to regulatory authorities in connection with our business or our affiliates (such as any of our funds). In addition, we share non-public personal information with certain service providers, to the extent permitted by law, and we require those service providers to keep the non-public information confidential. For example, we may provide such information to prime brokers, ISDA counterparties, attorneys, third-party marketing firms, fund administrators and auditors.
* We restrict access to non-public personal information about our clients and investors to employees and service providers who need to know that information to provide services to our clients.
* We maintain physical, electronic and procedural safeguards that comply with federal standards to guard clients’ and investors’ personal information.
3. COLLECTION OF INFORMATION
In general, you can browse the non-password protected sections of the Site without telling us who you are or revealing any personal information about yourself. We may automatically track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We may use this information to do internal research on our users’ demographics, interests and behavior to better understand, protect and serve you and our clients. This information may include the URL that you just came from (whether this URL is on the Site or not), which URL you next go to (whether this URL is on the Site or not), your computer browser information and your IP address. We would use this information to operate, develop and improve our services.
We also may use data collection devices such as “cookies” on certain pages of the Site to help analyze our web page flow, measure effectiveness, and promote trust and safety. “Cookies” are small files placed on your hard drive that assist us in providing our services. We may offer certain features that are only available through the use of a “cookie.” Cookies can also help us provide information that is targeted to your interests. Most cookies are “session cookies,” meaning that they are automatically deleted from your hard drive at the end of a session. You are always free to decline our cookies if your browser permits, although in that case you may not be able to use certain features on the Site and you may be required to reenter your password more frequently during a session. We use cookies to better understand how people interact with us.
4. USE AND DISCLOSURE OF INFORMATION
We use the information we collect from our browser and data collection devices such as cookies to improve our operations and facilitate, and improve, the services you request. We may use information collected from you to measure interest, customize your experience and enforce our Terms of Use.
We share the information you provide to us to apply for a password with us. We may use your information to send correspondence and perform services on your behalf in connection with investment related activities.
We may use personal information about you to analyze Site usage, improve our content and product offerings and customize the Site’s content, layout, and services. These uses improve the Site and better tailor it to meet your needs, so as to provide you with a smooth, efficient, safe and customized experience while using the Site. In connection with providing our services, it also may be necessary for us to share personal information about you with other third parties to help us process transactions relating to your account, including, but not limited to, asset transfers from a financial institution and processing or administering investment transactions and portfolios.
In certain instances, we may contract with third parties that are not affiliated with us to perform services for us, and, if necessary, we may disclose information about you to those third parties solely for the purpose of carrying out their assigned responsibilities. In those circumstances, we require those third parties to treat your private information confidentially. In some instances, the third-party service provider may collect information directly from you. In these cases, you will be notified of the involvement of the service provider, and all additional information you provide them and their additional uses will be strictly up to you. If you provide additional information to a service provider directly, their use of your personal information is governed by their privacy policy.
We may also share information about you if we believe that disclosure is required under law. For example, we may need to disclose information in response to a subpoena or to cooperate with regulatory or law enforcement authorities.
We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy. By way of example (without limiting the foregoing), we may be forced to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or service providers may abuse or misuse your personal information that they collect from the Site. Therefore, although we have adopted policies and procedures to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.
5. CONTROL OF YOUR PASSWORD AND PERSONAL INFORMATION
The Site contains a link to log in to the crosslink.sharesecurely.com (the “Sharesecure Site”), where you can access information about your investments in our funds. You are responsible for all actions taken with your Sharesecure Site user name and password. Therefore, we recommend that you do not disclose your password to any third parties. You may not allow others to use your user name or password to access or use any part of the Sharesecure Site.
We will retain in our files the personal information you have asked us to remove from our active databases to prevent fraud, resolve disputes, troubleshoot problems, assist with any investigations, enforce our Terms of Use and comply with legal requirements. Therefore, you should not expect that your personal information will be completely removed from our databases in response to your requests. However, such personal information will only be available to select employees, service providers and governmental persons or entities.
6. SECURITY
Your information is stored on a cloud based system, which may be in the United States. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure to protect your privacy, which may include encryption, “firewalls” and Secure Socket Layers. We treat data as an asset that must be protected against loss and unauthorized access. We employ security techniques to protect such data from unauthorized access by users inside and outside the company.
It is possible, however, that a third party will circumvent such security measures, and we do not guarantee that our security measures will successfully prevent third parties from accessing the information we collect. In the event of a security breach involving your personal information, we will make any legally required disclosures to you in the most expedient time possible and without unreasonable delay, consistent with the legitimate interests of law enforcement, or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
7. PHISHING
Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your username, password, credit card information or national identification number in an unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
8. CHILDREN
Children (persons under the age of 18) are not eligible to use the Site and, therefore, we do not knowingly collect any personal information from persons under the age of 18.
9. CONDITIONS OF USE
If you choose to visit the Site, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages and application of the law of the State of California. If you have any concern about privacy, please send a thorough description to ir@crosslinkcapital.com
10. CHANGES TO THIS POLICY
Please note this Privacy Policy may change from time to time. We may amend this Privacy Policy at any time by posting the amended terms on the Site. All amended terms shall automatically be effective 30 days after they are initially posted on the Site. Your continued use of the Site constitutes your agreement to this Privacy Policy and any changes to this Privacy Policy. If we make any material changes to this Privacy Policy that affect your information already stored in our database, we will post a prominent notice on the Site stating that this Privacy Policy has changed. If you do not agree with this Privacy Policy or any changes to the Privacy Policy, please do not use or access the Site.
If you have any additional questions, please feel free to contact us any time at ir@crosslinkcapital.com