What personal information do we collect from the people that visit our blog, website or app?
When ordering or registering on our site, as appropriate, you may be asked to enter your name, email address or other details to help you with your experience.
When do we collect information?
We collect information from you when you register on our site, place an order, subscribe to a newsletter or enter information on our site.
How do we use your information?
We may use the information we collect from you when you register, make a purchase or investment commitment, sign up for our newsletter, respond to a survey or marketing communication, browse the website, or use certain other site features in the following ways:
How do we protect visitor information?
We do not use vulnerability scanning and/or scanning to PCI standards. We use periodic Malware scanning. Your personal information is contained behind secured networks and is only accessible by a limited number of persons who have special access rights to such systems and are required to keep the information confidential. In addition, all sensitive/credit information you supply is encrypted via Secure Socket Layer (SSL) technology.
We implement a variety of security measures when a user places an order or enters, submits, or accesses their information to maintain the safety of your personal information.
We do not process credit card or payment transactions on our servers, nor do we store any personal financial information.
Do we use ‘cookies’?
You can choose to have your computer warn you each time a cookie is being sent, or you can choose to turn off all cookies. You do this through your browser (like Internet Explorer) settings. Each browser is a little different, so look at your browser’s Help menu to learn the correct way to modify your cookies.
If you disable cookies, some features will be disabled and some of our services will not function properly.
However, you can still browse investment opportunities and place investment orders.
Third Party Disclosure
We do not sell, trade, or otherwise transfer to outside parties your personally identifiable information unless we provide you with advance notice. This does not include website hosting partners and other parties who assist us in operating our website, conducting our business, or servicing you, so long as those parties agree to keep this information confidential. We may also release your information when we believe release is appropriate to comply with the law, enforce our site policies, or protect ours or others’ rights, property, or safety.
Third party links
Occasionally, at our discretion, we may include or offer third party products or services on our website. These third-party sites have separate and independent privacy policies. We therefore have no responsibility or liability for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our site and welcome any feedback about these sites.
Google’s advertising requirements can be summed up by Google’s Advertising Principles. They are put in place to provide a positive experience for users. https://support.google.com/adwordspolicy/answer/1316548?hl=en
We use Google AdSense Advertising on our website.
We have implemented the following:
We along with third-party vendors, such as Google use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) or other third-party identifiers together to compile data regarding user interactions with ad impressions, and other ad service functions as they relate to our website.
Users can set preferences for how Google advertises to you using the Google Ad Settings page. Alternatively, you can opt out by visiting the Network Advertising initiative opt out page or permanently using the Google Analytics Opt Out Browser add on.
California Online Privacy Protection Act
According to CalOPPA we agree to the following:
Users are able to change their personal information:
How does our site handle do not track signals?
We will still collect and use your browsing data to improve security, to provide content, services and recommendations and to generate reporting statistics.
Does our site allow third party behavioral tracking?
It’s also important to note that we allow third party behavioral tracking.
COPPA (Children Online Privacy Protection Act)
When it comes to the collection of personal information from children under 13, the Children’s Online Privacy Protection Act (COPPA) puts parents in control. The Federal Trade Commission, the nation’s consumer protection agency, enforces the COPPA Rule, which spells out what operators of websites and online services must do to protect children’s privacy and safety online.
We do not specifically market to children under 13.
Fair Information Practices
The Fair Information Practices Principles form the backbone of privacy law in the United States and the concepts they include have played a significant role in the development of data protection laws around the globe. Understanding the Fair Information Practice Principles and how they should be implemented is critical to comply with the various privacy laws that protect personal information.
In order to be in line with Fair Information Practices we will take the following responsive action, should a data breach occur:
We will notify the users via email.
We will notify the users via in site notification.
We also agree to the individual redress principle, which requires that individuals have a right to pursue legally enforceable rights against data collectors and processors who fail to adhere to the law. This principle requires not only that individuals have enforceable rights against data users, but also that individuals have recourse to courts or a government agency to investigate and/or prosecute non-compliance by data processors.
CAN SPAM Act
The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations.
We collect your email address in order to:
To be in accordance with CANSPAM we agree to the following:
If at any time you would like to unsubscribe from receiving future emails, you can follow the instructions at the bottom of each email, and we will promptly remove you from ALL correspondence.
Changing or Removing Information; Opting Out
Applicable law places certain obligations on investors to keep information current, including, for example, Form W-9 Information. It is particularly important for you to keep your financial information current and to report to us any material change in this Information. We use this information to provide you with investment opportunities and financial distributions due to you as an equity or debt holder in an investment opportunity in which you have invested through our website. Without current information, you receive information in error or that you are not eligible to receive or act on. To allow appropriate control over PII, you can access your account (after supplying your username and password) to change or update discretionary information that you have previously submitted. You are entitled to decline to participate in certain Services and to decline to give us permission (or to revoke that permission in your discretion) to use your PII for certain purposes. We provide you with the ability to opt-out of receiving communications concerning, or being included in, these activities. To opt-out of Services for which an opt-out right is available, please email us at firstname.lastname@example.org. We can also answer questions or assist if you contact us as provided herein. You will not be allowed to opt–out of required notices or other legal and related notices concerning your relationship to the website. If you request, we will remove your name and all other PII from our databases. It may be impossible to remove this information completely, due to IRS and regulatory reporting requirements, ownership in an investment opportunity in which you have invested through our website and the rights thereof, data backups and records of deletions. If you request deletion of your information, you will be unable to use certain features of the website and any associated Services. You may not remove de-identified, anonymous, or aggregate data from our databases.
Third Party Access to PII
Anonymous, Aggregate Information
Notice of Security Incident
If we detect, despite the safeguards set out above, an intrusion or other unauthorized access to or use of PII, we will (i) notify affected users of the intrusion if we determine that the information at issue is sensitive; (ii) deliver this notice by the means we deem most efficient under the circumstances (such as, for example, first class mail or email); (iii) use contact information for each affected user in our files; and (iv) use commercially reasonable efforts to accomplish these steps and effect this notice in a timely manner. To the extent Applicable Law requires steps in addition to those specified above, we will under all circumstances comply with applicable law.
DST Investment Advisors
15169 N. Scottsdale Rd. #205
Scottsdale, AZ 85254