Privacy NOTICE.
This Privacy Notice describes how Dille & Koo, LLC and its affiliates (collectively, “we”) collect, use, store and disclose personal information about those who engage with us for investment services.
Our collection, use, storage and disclosure of personal information is limited to what is necessary to provide you with the services you have requested or authorized. We do not collect, store, use or disclose personal information for any other purpose.
Information We Collect and Disclose. We only collect, use, store and disclose your personal information where we have a lawful basis to do so. We, including parties acting on our behalf or our affiliates behalf (such as our service providers), collect and disclose (for the purposes described below) several types of personal information, including:
• Information you or your financial representative provides us on forms used in connection with your investments, in other electronic or written communications and during telephone or in person meetings (such information may include your name, residential and business addresses, citizenship, birthdate, email address, telephone numbers and other contact information, household income and net worth, investment qualification and background, social security number or taxpayer identification number, passport information, driver’s licenses, information on your tax forms, and other information necessary for us to market our services to you or comply with laws and regulations that apply to our investment operations);
• Information about the amounts you have invested with us, such as your initial investment, current account balances and any subscriptions or withdrawals;
• Information about any bank account used to transfer funds between your investment with us and your bank, including information provided for wire transfers; and
• Information we receive from third parties, including information from referral sources, and information that is generated by our service providers, such as administrators, accountants, bankers and custodians, to service our investors and accounts (such as account statements, tax information reports, transaction records and confirmations of contributions and withdrawals and similar information).
We may collect Investor Data through our website (the “Site”). The Site uses “cookies”, which may automatically collect certain information and data. “Cookies” are small pieces of data sent to your computer browser from our web server and stored on your computer’s hard drive. The data identifies you as a unique user and facilitates your ongoing access to and use of the Site. Cookies also help us diagnose problems with our server and the Site. If you don't want us to use cookies when you use the Site, you can adjust your internet browser settings not to accept cookies. Your web browser's help function should tell you how to do this. Alternatively, to find out more about cookies, including how to see what cookies have been set and how to manage and delete them, visit the website: http://www.allaboutcookies.org. This website will also explain how you can delete cookies which are already stored on your device. However, without these identifier files you may not have access to many features that may make your browsing of the Site smoother, and some of our services may not function properly. The Site does not respond to “Do Not Track” signals.
If you provide personal information about any person other than yourself, you must ensure they understand how their personal information will be used and that they have given their permission for you to disclose their personal information.
Use of Your Personal Information. We use your personal information for the following limited business purposes and as otherwise described in this Privacy Notice:
· To evaluate and effect investment transactions and contracts, manage the investment services we provide you and help maintain the administration, safety, security and integrity of our business and assets;
· To comply with any applicable compliance, legal and regulatory obligations, lawful requests and legal processes (such as to respond to subpoenas and requests during government investigations) as we believe appropriate, and to comply with the compliance obligations required by our service providers;
To communicate with you about investments, our other services and products, and updates regarding our firm;
To improve the services provided to you, as well as understand your interests and personalize your experiences with us; anD On occasion, we may ask for your consent to use your personal information for purpose(s) we explain at that time.
Who Receives Disclosed Information. It is our policy to not disclose your personal information, except we may disclose your personal information as permitted by law to the following types of parties:
· Our affiliates, for our and our affiliates’ purposes consistent with this Privacy Notice;
Service providers that act on our behalf and help us with our operations (for example, administrators or companies that assist us with processing transactions, generating financial reports, data processing, tax filings, technology services and maintaining books and records), provided, that these third parties may use your personal information only as authorized by their contracts with us;
Our professional advisors, such as lawyers, bankers, accountants, brokers and insurers in the course of the professional services that they render to us;
· Any third party as required to comply with a law, regulation, or legal request (including for anti-money laundering purposes, know your customer requirements, tax reporting, as we believe necessary or appropriate to comply with lawful requests and legal process, such as a request from a government authority, and in response to requests from self-regulatory organizations and non-governmental regulators), for fraud prevention, or to protect the property or rights of us or others (however, nothing in this notice is intended to limit any legal defenses or objections that you may have to a third party or government request to disclose your information); and
Any third party to which you direct us to disclose your personal information or which you consent to the disclosure of your personal information.
We do not sell your personal information.
Information Security. We maintain physical, electronic and procedural safeguards to guard your personal information and the integrity and security of our databases. We have procedures in place for the disposal and protection against unauthorized access or use of your information. Except as described above, access to non-public personal information is restricted to our personnel who need to know such information. If we disclose your personal information, it is made available for limited purposes and under controlled circumstances.
Children. Our services are not directed to and we do not knowingly collect or solicit personal information from anyone under the age of 16 without parental or guardian consent.
Data Retention. We retain your personal information during the period you are an investor with us and for as long as is otherwise permitted by applicable law, necessary to resolve disputes, or necessary for legitimate business or legal purposes.
Changes to this Privacy Notice. We reserve the right to change our Privacy Notice in the future. If we make changes that materially affect how we collect, use, store and disclose your personal information, we will notify you.