Capital Allocators Partners, LLC, a Delaware limited liability company (also referred to as “we,” “our”, or “us”) provides this Privacy Policy (this “Policy”) to inform you about our collection, use, disclosure, and storage of data about you that we collect via this website and the content, functionality, and services on our website, which we refer to collectively as the “Website.” You agree to this Policy, and other policies on our Website by using the Website or by accepting this Policy in connection with creating an account with us.
Changes to this Policy. We may change this Policy from time to time, and such changes will be effective upon our posting a new version on the Website. We will also update the date at the top of this Policy to reflect the effective date of any such changes, and we encourage you to periodically review this Policy for any updates. Your continued use of the Website and/or creation of an account after we have posted an updated version of this Policy will automatically constitute your acceptance of such version.
Information We Collect and Receive. We may collect and process some or all of the following types of information about you:
While Usage Information is non-identifying on a standalone basis, we may in certain instances combine this information with other information collected on the Website. If we ever combine non-identifying information with Personal Information or other information that enables you to be identified, we will treat such combined information as Personal Information. We do not currently use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you.
How We Collect and Receive Information. We collect Personal Information and Usage Information in the following ways:
How We Use Information. We use Personal Information in the following ways:
You can opt out of receiving promotional or marketing emails from us at any time by clicking the unsubscribe, opt-out, or similar link at the bottom of any such emails. Please note we may still contact you for non-marketing reasons (e.g., in connection with your membership, events you have registered for or attended, or any other transactions involving you).
We may use Usage Information (which does not identify you personally) for any manner we deem appropriate, including without limitation to improve, maintain, and operate the Website.
How We Share Information. We will not sell your Personal Information to third parties. We may share your Personal Information with our affiliates and as needed to fulfill the purposes described in the “How We Use Information” section above, including:
Additionally, in the event of a merger, consolidation, sale, or transfer of all or substantially all of our assets or business, one of the assets that would generally be transferred is the data we have collected, which would be transferred subject to the applicable version of this Policy.
We may disclose Usage Information (which does not identify you personally) to any parties and for any purposes we deem appropriate.
Your California Privacy Rights. This section provides additional details about the Personal Information we may collect about California-resident Users and the rights afforded to them under California Civil Code Section 1798.83 and the California Consumer Privacy Act of 2018 (“CCPA”). California-resident users are entitled to additional privacy rights which are further described below. California-resident users who wish to request further information about our compliance with the above referenced statutes or who have questions more generally about our Privacy Policy or the CCPA and our privacy commitments to our users should not hesitate to contact us in accordance with the procedures set forth below.
California Residents’ Rights and Choices with Respect to Personal Information. Subject to certain limitations, the CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights, which specifically includes:
Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights subsection below), we will disclose to you:
Deletion Request Rights. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at info@capitalallocators.com
Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:
Making a verifiable consumer request does not require you to create an Account with us. However, we do consider requests made through your password protected Account sufficiently verified when the request relates to Personal Information associated with that specific account. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format. We endeavor to respond to a verifiable California residents request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
Personal Information Sales Opt-Out and Opt-In Rights. We will not sell your Personal Information to any party. If in the future, we anticipate selling your Personal Information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA.
Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
European Union Users. European Union data protection law requires a “lawful basis” for collecting and retaining Personal Information from citizens or residents of the European Economic Areas (“EEA”). Our lawful basis for collecting such information about you is permitted under Article 6, Sections 1(a), 1(b), 1(c) and 1(f) of the EU general data protection regulation 2016/679 (“GDPR”), which are summarized below.
To the extent established under applicable law, European Union or Swiss residents may have the right:
To make any of the above requests, please contact us as set forth at the end of this Policy. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Information, you may be charged a fee to the extent permitted by law.
Cookies. If you have permitted your computer to accept “cookies,” we may use “cookies” to keep, and sometimes track, information about you. Cookies are small data files that are sent to your browser or related software and apps, from a Web server and stored on your mobile device, or computer’s hard drive. Cookies track where you travel on our Website and what you look at, transact and favorite. They may store the information in your account, and/or your Username and/or password, and we may use them to deliver specific messages to you (for example, to announce a new property that was added since the last time you visited the Website). A cookie may enable us to link your use of our Website to other information about you, including your Personal Information. All of these purposes serve to improve and personalize your experience on our Website. Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Website or certain areas or features of the Website.
Do Not Track Requests. Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online service you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit http://www.allaboutdnt.com.
Location and Security. We are based in the United States. By using the Website, you consent to your Personal Information being transferred to and stored in the United States. The security of your information is important to us, and we take steps to ensure that your information is treated securely and in accordance with applicable laws. Unfortunately, the transmission of information via the internet is not completely secure, and any transmission is at your own risk. We follow generally accepted industry standards to protect your information, both during transmission and once we receive it, and to keep such Information confidential (unless it is non-confidential by nature, for example, publicly available information or information you post on public portions of the Website). In the unlikely event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate such information. If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately. Children. The Website is not directed toward children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, the parent or guardian should contact us as set forth at the end of this Policy, and we will take reasonable steps to promptly remove such data from our systems (subject to any applicable, legally required or permitted, retention standards).
Third Party Sites. The Website may include links to third party sites and services. If you visit or use such third party sites and services, please be mindful that the relevant third party controls the cookies and other technologies it uses on its sites and how it collects, uses, and shares your information. This Policy only governs our own privacy practices; please review the applicable third party privacy policy when visiting or using any third party sites or services.
Contacting Us. If you have any questions or comments about this Policy, the ways in which we collects and uses your information described above and generally, your choices and rights regarding such use, or wish to exercise your rights under applicable privacy law, please do not hesitate to contact us by email at info@capitalallocators.com.