Effective Date: September 1, 2021
By creating an account on the Site or by otherwise submitting Personal Information to us through the Site, you give your consent to the collection and use of your Personal Information as explained in this Policy you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of Cambrian and the authorized third parties referred to herein located in the United States.
If you request information through the Site or to us, we may require you to provide us with certain information, such as your name, country, email address, and investor accreditation status.
If you register an Account on the Service, then you must provide us with certain information, such as your name, address, and contact email address. Additionally, as a part of the subscription process, we may collect certain other information from you, such as your tax ID number, social security number, and information concerning your financial history, income, and net worth. If you are accessing the Service on behalf of an organization, you may be required to provide the information about the organization, such as its certificate of incorporation and date of formation.
In order to process payments of amounts you invest in a Fund, we collect certain payment information, including your bank routing numbers, bank account numbers, and billing address.
We collect information about your use of the Service. For example, we collect the information that you provide to us in connection with accessing the Investor Portal to view the performance of a Fund or your investment in a Fund.
If you contact us directly, we may receive additional information about you. For example, when you contact us through our general investor email address, we may receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide.
We collect and store your location information if you enable your device to send it to us, such as by use of geolocation features in the device(s) through which you access the Service, or by inference from other information we collect (for example, your IP address indicates the general geographic region from which you are connecting to the Internet).
The Service collects and stores information that is generated automatically as you use it, including your preferences and anonymous usage statistics.
When you visit the Service, we and our third-party service providers receive and record information on our server logs from your browser, including your IP address, and from cookies and similar technology. Our service providers may collect information about your online activities over time and across different online services. Cookies are small text files placed on your computer browser when you visit a website. Most browsers allow you to block and delete cookies. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the Service features.
By using the Service, you are authorizing us to gather, parse, and retain data related to the provision of the Service.
We are not in the business of selling your Personal Information; however there are certain circumstances in which we may share your Personal Information with certain third parties without further notice to you, as set forth below. We use information, including unique identifiers and your location for internal and service-related purposes, such as data analytics, and may share this information with service providers to allow us to provide, maintain, and improve the Service.
We may send email to the email address you provide to us to verify your account and for informational and operational purposes, such as account management, customer service, system maintenance, or to inform you about additional products or services that may be of interest to you.
In an ongoing effort to better understand and serve the users of the Services, we often conduct research on its customer demographics, interests and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregated and/or de-identified basis, and we may share this aggregated and/or de-identified data with our affiliates, agents and business partners. We may also disclose aggregated and/or de-identified user statistics and other metrics related to our Services in order to describe our products or services to current and prospective business partners and to other third parties for other lawful purposes.
We may use the information collected through the Service to enforce our Terms of Service or other legal rights.
We may share any information that we receive through the Service with vendors and service providers retained in connection with the provision of the Service, including our payment processors, auditors, and other vendors for data analytics purposes.
We may also disclose your information with your permission.
We limit access to the Personal Information you provide us to those employees who need access to that information in order to provide you with services related to the transactions you are entering into through the Sites. In keeping with industry standards and practices, we maintain appropriate physical, electronic and procedural safeguards, and controls designed to protect your Personal Information.
We have invested in software, systems and procedures aimed at offering you a safe and secure transaction environment and protect your personal, financial and historical transaction information. While no security system is absolutely impenetrable, we plan to constantly review, refine and upgrade our security technology as new tools become available.
We will delete your Personal Information when it is no longer needed for these purposes. If we cannot delete it, for technical reasons, entirely from our systems, we will put in place appropriate measures to prevent any further processing or use of the data.
We have security standards and procedures in place designed to prevent unauthorized access to your Personal Information. A key part of this process helps ensure that the Personal Information we have about you is accurate and up-to-date. If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately. We only use your Personal Information as appropriate to provide you with quality services and to ensure security. For example, we may use the information collected from you to verify your identity and contact information.
Subject to applicable local law, you have rights regarding your Personal Information, including: access, rectification, erasure and blocking, restriction of use, objection to use, data portability, and the lodging of a claim to your local data protection authority.
We are just as committed to protecting the privacy of our former clients as we are our current clients. If you choose to become an inactive client, your Personal Information will continue to be protected by the privacy policies and principles described in the then-current version of this Policy. Should you redeem or otherwise dispose of your investments with us, Cambrian will retain your information for regulatory compliance, internal record-keeping and other legal purposes.
We take commercially reasonable steps to protect the Personal Information provided via the Services from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no Internet or email transmission is ever fully secure or error free. In particular, email sent to or from the Services may not be secure. Therefore, you should take special care in deciding what information you send to us via email. Please keep this in mind when disclosing any Personal Information to us via the Internet.
Some web browsers incorporate a “Do Not Track” feature. Because there is not yet an accepted standard for how to respond to Do Not Track signals, our website does not currently respond to such signals.
We do not knowingly collect, maintain, or use personal information, as defined by the Federal Trade Commission’s Children’s Online Privacy Protection Act (“COPPA”) Rule, from children under 13 years of age, and no part of the Service is directed to children under the age of 13. If we learn that we have collected any personal information from children under 13, then we will promptly take steps to delete such information and terminate the child’s account.
You may contact us at ir@Cambrianasset.com.