Privacy Policies

COLLECTIVE ASSET MANAGEMENT, LLC

The Collective Asset Management, LLC Privacy Policy (“Privacy Policy”) is intended to acquaint you with Collective Asset Management, LLC’s (“Collective Asset Management,” or the “Firm”) policies regarding information and system security. This Privacy Policy describes how your personal information is collected, used, and shared when you visit or make a purchase from https://www.collectiveliquidity.com (the “Site”). In this Privacy Policy, “we,” “us” and “our” refers collectively to Collective Asset Management and its affiliates and/or delegates and investment funds and accounts managed, advised, or administered by Collective Asset Management (each, a “Fund” and collectively, the “Funds”).

This Privacy Policy is provided to you in order for us to comply with the California Consumer Privacy Act of 2018 (“CCPA”) and other relevant federal and California privacy laws. Any terms defined in the CCPA have the same meaning when used in this notice.

I. PERSONAL INFORMATION WE COLLECT

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly with a particular consumer or device (“Personal Information”). Personal Information includes, but is not limited to, the following if it identifies, relates to, describes, is capable of being associated with, or could be reasonably linked, directly or indirectly, with a particular consumer or household.

We collect the following categories of Personal Information from consumers:


A. CATEGORY: Identifiers

EXAMPLE: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.

COLLECTED: YES


B. CATEGORY: Financial information and other personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))

EXAMPLE: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some personal information included in this category may overlap with other categories.

COLLECTED: YES


C. CATEGORY: Protected classification characteristics under California or federal law

EXAMPLE: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).

COLLECTED: NO


D. CATEGORY: Commercial information

EXAMPLE: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

COLLECTED: NO


E. CATEGORY: Biometric information

EXAMPLE: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.

COLLECTED: NO


F. CATEGORY: Internet or other similar network activity

EXAMPLE: Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.

COLLECTED: NO



G. CATEGORY: Geolocation data

EXAMPLE: Physical location or movements.

COLLECTED: NO


H. CATEGORY: Sensory data

EXAMPLE: Audio, electronic, visual, thermal, olfactory, or similar information.

COLLECTED: NO


I. CATEGORY: Professional or employment-related information

EXAMPLE: Current or past job history or performance evaluations.

COLLECTED: NO


J. CATEGORY: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99))

EXAMPLE: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

COLLECTED: NO


K. CATEGORY: Inferences drawn from other personal information

EXAMPLE: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

COLLECTED: NO


We obtain the categories of personal information listed above from the following categories of sources:

  • Directly from consumers or their agents, both in writing and orally. For example, from documents that our clients provide to us related to the services for which they hire us.
  • Indirectly from consumers or their agents. For example, through information we collect from our clients in the course of providing services to them.
  • Directly and indirectly from activity on our website (https://www.collectiveliquidity.com/) and interactions with our electronic communications. For example, from submissions through our website portal or website usage details collected automatically.
  • From third-parties that interact with us in connection with the services we perform. For example, from custodians or broker-dealers who provide financial services to our clients.

In addition, we automatically collect certain data from individuals who visit our website. When you visit the Site, we automatically collect certain information about your device, including information about your web browser, IP address, time zone, and some of the cookies that are installed on your device. Additionally, as you browse the Site, we collect information about the individual web pages or products that you view, what websites or search terms referred you to the Site, and information about how you interact with the Site. We refer to automatically-collected information as “Device Information.”

We collect Device Information using the following technologies:

  • Cookies. “Cookies” are data files that are placed on your device or computer and often include an anonymous unique identifier. For more information about cookies, and how to disable cookies, visit http://www.allaboutcookies.org.
  • Log files. “Log files” track actions occurring on the Site, and collect data including your IP address, browser type, Internet service provider, referring/exit pages, and date/time stamps.
  • Web beacons. “Web beacons,” “tags,” and “pixels” are electronic files used to record information about how you browse the Site.

Personal information does not include:

  • Publicly available information from government records.
  • Deidentified or aggregated consumer information.
  • Information excluded from the CCPA's scope, like health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data.
  • Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

II. USE OF PERSONAL INFORMATION

We may use or disclose the personal information we collect for one or more of the following business purposes:

  • To fulfill or meet the reason you provided the information to us. For example, if you provide us with personal information so that we can provide you with financial advice, we may use the information to tailor such advice to your circumstances. Similarly, if you hire us to provide discretionary asset management services, we may use the information as necessary to transmit instructions to third-parties to facilitate securities transactions or related activities on your behalf.
  • To provide you with other information, products, or services that you request from us.
  • To create, maintain, customize, and secure your account with us.
  • To process your requests, transactions, and payments and prevent fraud.
  • To provide you with notifications, reports, statements, invitations and other notices concerning products, services, events, or news that you may request or that may be of interest to you.
  • To carry out our obligations and enforce our rights arising from any contracts between you and us, including for billing and collections.
  • To improve our website and electronic communications, present their contents to you, and maintain their security.
  • As necessary or appropriate to protect the rights, property or safety of us, our clients or others.
  • To respond to law enforcement and regulatory agency requests, as required by applicable law, court order, or governmental regulations.
  • As described to you when collecting your personal information or as otherwise set forth in the CCPA.
  • To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by us is among the assets transferred.

We will not collect additional categories of your personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice. Should we wish to use Personal Information for other specific purposes, we will contact you or provide you with other prior notice.

III. SHARING YOUR PERSONAL INFORMATION

We do not sell any Personal Information to unaffiliated third-parties and have not sold any Personal Information in the past 12 months.

We may provide your Personal Information to our affiliates and to firms that assist us in servicing your account and have a need for such information.

Such affiliates and firms we will share your Personal Information with include, but are not limited to:

(1) The fund administrator, and its respective affiliates for the purposes set out in this Notice, which include:

  • managing our relationship with you;
  • delivering the services you require;
  • managing your investment;
  • supporting and administering investment-related activities;
  • complying with applicable investment laws and regulations;
  • delivering and facilitating the services needed to support our business relationship with you; and
  • supporting and administering investment-related activities,

(2) tax authorities:

  • to comply with applicable laws and regulations; and
  • where required by tax authorities (who, in turn, may share your personal data with other tax authorities),

(3) our lawyers, auditors and other professional advisors for purposes of:

  • providing you with investment-related services; and
  • seeking advice on, and complying with, legal and regulatory requirements or legal rights and obligations.


We may share Personal Information for purposes including the following:

(1) The processing is necessary for the performance of a contract, for example:

  • administering or managing the Fund;
  • processing your subscription and investment in the Fund, such as entering your information in the register of shareholders;
  • sending you statements relating to your investment;
  • providing advisory services to you;
  • opening an account for you; and
  • processing a transaction for your account.

(2) In pursuance of our legitimate interests, or those of a third party to whom your personal data are disclosed, for example:

  • complying with a legal, tax, accounting or regulatory obligation to which we or the third party are subject;
  • assessing and processing requests you make;
  • managing our risk and operations;
  • complying with audit requirements;
  • ensuring internal compliance with our policies and procedures; and
  • marketing products and services to you.

(3) The processing is necessary for compliance with applicable legal or regulatory obligations, for example:

  • undertaking investor due diligence including anti-money laundering and counter-terrorist financing checks, including verifying the identity and addresses of our investors (and, where applicable, their beneficial owners);
  • sanctions screening and complying with applicable sanctions and embargo legislation;
  • complying with requests from regulatory, governmental, tax and law enforcement authorities; and
  • responding to court orders and legal investigations.

In exceptional circumstances, we will share your Personal Information with regulatory, prosecuting and other governmental agencies or departments, and parties to litigation (whether pending or threatened) in any country or territory, as and to the extent required by law.

We will only process your personal data in pursuance of our legitimate interests where we have considered that the processing is necessary and, on balance, our legitimate interests are not overridden by your legitimate interests, rights or freedoms.

IV. RETENTION OF PERSONAL INFORMATION

We retain Personal Information for as long as required by us to meet contractual obligations and perform services or comply with applicable legal or regulatory obligations. For example, we may require Personal Information for our legitimate business purposes, to perform our contractual obligations, or where law or regulation obliges us to. We expect to delete your Personal Information (at the latest) once there is no longer any legal or regulatory requirement or legitimate business purpose for retaining your personal data.

V. HOW DO WE PROTECT PERSONAL INFORMATION?

We apply appropriate technical, physical, and administrative information security measures designed to protect against unauthorized or unlawful processing of Personal Information, and against accidental loss or destruction of, or damage to, Personal Information.

VI. CHILDREN’S PRIVACY

We are committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. Our services are not intended for and may not be used by children under the age of 13. We do not knowingly collect information from children under the age of 13 and we do not target children under the age of 13.

VII. NON-DISCRIMINATION

Under the CCPA, you cannot be discriminated against for exercising your rights to access or request erasure of your Personal Information.

VIII. CALIFORNIA SHINE THE LIGHT DISCLOSURE

California’s “Shine the Light” law permits California residents to annually request and obtain information free of charge about what personal information is disclosed to third parties for direct marketing purposes in the preceding calendar year. We do not distribute your personal information to outside parties without your consent for their direct marketing.

IX. RIGHTS UNDER CCPA

You have certain rights under the CCPA. These include the right to: (i) request the deletion of your Personal Information that we collect or maintain; (ii) opt out of the sale of Personal Information; and (iii) obtain a copy of your Personal Information in a portable format.

X. HOW TO EXERCISE YOUR CCPA RIGHTS

Individuals who submit requests for access or erasure of Personal Information will be required to verify their identity by answering certain questions. We will not disclose or delete any information until such individual’s identity is verified.

If you are making a request for access, we may not be able to provide specific pieces of Personal Information if the disclosure creates a substantial, articulable, and unreasonable risk to the security of your Personal Information, your account with us, or our systems or networks.

If you are making a request for erasure, we will ask that you confirm that you would like us to delete your Personal Information again before your request is submitted. In certain circumstances, we may not erase all Personal Information, as permitted by the CCPA.

You may designate an authorized agent to submit a request on your behalf by providing that agent with your written permission. If an agent makes a request on your behalf, we may still ask that you verify your identity directly with us before we can honor the request.

Agents who make requests on behalf of individuals will be required to verify the request by submitting written authorization from the individual. We will not honor any requests from agents until authorization is verified.

XI. COMPLAINTS

We take very seriously any complaints we receive about our use of Personal Information. Please contact us using the information below if you have any questions, comments, requests or complaints regarding this Privacy Policy, or if you wish to discuss your data protection rights with us.

XII. CONTACT INFORMATION

To exercise any of your rights or if you would like to discuss any questions or concerns, please contact us by writing to us at [email protected].

Collective Asset Management, LLC

4554 Broad Street, #100

San Luis Obispo, CA 93401


XIII. CHANGES TO OUR PRIVACY POLICY

We reserve the right to amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will notify you by email or through a notice on our website homepage.

Collective Liquidity Inc. Privacy Policy

Your privacy is important to us. This Online Privacy Policy explains how we collect, share, use, and protect information when you visit or use this website (“Online Services). This policy covers Collective Liquidity’s Online Services as well as any interactions you may have while viewing content provided through one of Collective Liquidity’s digital advertising campaigns.

As you review this Online Privacy Policy, here are a few general principles to keep in mind:

  • Our Online Services are intended for a U.S. audience. If you visit or use one of our Online Services, your information will be transferred to or processed in the United States.
  • Our Online Services are not intended for children under 18. We do not knowingly collect personal information from children under 18.
  • If you have a financial product or service through us, we will use and share any information that we collect from or about you in accordance with our Privacy Notice, which is available (link: soon). The Privacy Notice for WebBank, the lender for the Exchange Loan, may be viewed at (link: soon). A Privacy Notice explains how personal information is collected, used and shared about you and offers you certain choices with respect to the use and sharing of your personal information.
  • If you have questions after reviewing this policy, please contact us at 1-888-977-5228.

Information we Collect

Personal Information
When you visit or use our Online Services, we may collect personal information from or about you such as your name, email address, mailing address, telephone number(s), account numbers, username and password. We may also collect social security numbers, driver’s license numbers (or comparable) when you provide such information while using our Online Services and where we believe it is reasonably required for ordinary business purposes.

Usage and Other Information
In addition to the personal information described above, we may collect certain information about your use of our Online Services. For example, we may capture the IP address of the device you use to connect to the Online Services, the type of operating system and browser you use, and information about the site you came from, the parts of our online service you access, and the site you visit next. We or our third-party partners may also use cookies, web beacons or other technologies to collect and store other information about your visit to, or use of, our Online Services. In addition, we may later associate the usage and other information we collect online with personal information about you.

Additional Sources of Information
We may also collect information about you from additional online and offline sources including from co-branded partner sites or commercially available third-party sources, such as credit reporting agencies when we process applications on behalf of WebBank. We may combine this information with the personal and other information we have collected about you under this Online Privacy Policy.

Use of Information

  • We use the information discussed above in a number of ways, such as:
  • Processing applications and transactions;
  • Verifying your identity (such as when you access your account information);
  • Preventing fraud and enhancing the security of your account or our Online Services;
  • Responding to your requests and communicating with you;
  • Managing your preferences;
  • Performing analytics concerning your use of our Online Services, including your responses to our emails and the pages and advertisements you view;
  • Providing you tailored content and marketing messages;
  • Operating, evaluating and improving our business (including performing data analytics; and performing accounting, auditing and other internal functions);
  • Complying with and enforcing applicable legal requirements, relevant industry standards, contractual obligations and our policies; and
  • For any other purposes that we may specifically disclose at the time you provide, or we collect your information.

We may also use data that we collect on an aggregate or anonymous basis (such that it does not identify any individual customers) for various business purposes, where permissible under applicable laws and regulations.

Disclosure of Information

We may share the information we collect from and about you with our affiliates and other third parties. For example, we may share your information with:

  • Collective Liquidity third-party service providers;
  • Third parties or affiliates in connection with a corporate transaction, such as a sale, consolidation or merger of Collective Liquidity businesses; and
  • Other third parties to comply with legal requirements such as the demands of applicable subpoenas and court orders; to verify or enforce our terms of use, our other rights, or other applicable policies; to address fraud, security or technical issues; to respond to an emergency; or otherwise to protect the rights, property or security of our customers or third parties.

Where appropriate, we will limit sharing of your information in accordance with the choices you have provided us in response to either our Collective Liquidity Privacy Notice or the WebBank Privacy Notice.

We may share anonymous or aggregated information with third parties to help deliver content that is tailored to the users of our Online Services and for other purposes.

Understanding Cookies, Web Beacons and Other Tracking Technologies

We, or our service providers, and other companies we work with may deploy and use cookies, web beacons, local shared objects and other tracking technologies for various purposes, such as fraud prevention and monitoring our advertising and marketing campaign performance. Some of these tracking tools may detect characteristics or settings of the specific device you use to access our Online Services.

“Cookies” are small amounts of data a website can send to a visitor’s web browser. They are often stored on the device you are using to help track your areas of interest. Cookies may also enable us or our service providers and other companies we work with to relate your use of our Online Services over time to customize your experience. Most web browsers allow you to adjust your browser settings to decline or delete cookies but doing so may degrade your experience with our Online Services.

Clear GIFs, pixel tags or web beacons—which are typically one-pixel, transparent images located on a webpage or in an email or other message—or similar technologies may be used on our sites and in some of our digital communications (such as email or other marketing messages). They may also be used when you are served advertisements, or you otherwise interact with advertisements outside of our Online Service. These are principally used to help recognize users, assess traffic patterns and measure site or campaign engagement.

Local Shared Objects, sometimes referred to as “flash cookies” may be stored on your hard drive using a media player or other software installed on your device. Local Shared Objects are similar to cookies in terms of their operation but may not be managed in your browser in the same way.

Do Not Track

Many web browsers possess a do-not-track feature that lets your browser tell websites you visit that you do not want to have your online activities tracked. At this time, our Online Services do not respond to browser do not track signals.

Linking to Third-Party Websites

Collective Liquidity may provide links to websites that are owned or operated by other companies ("third-party websites"). When you use a link online to visit a third-party website, you will be subject to that website’s privacy and security practices, which may differ from ours. We expressly disclaim any responsibility liability for all content made available to you on third-party websites. You should familiarize yourself with the privacy notice/policy, terms of use and security practices of the linked third-party website before providing any information on that website.

Security

We use reasonable physical, electronic, and procedural safeguards that comply with federal standards to protect and limit access to personal information. This includes device safeguards and secured files and buildings.

Please note that information you send to us electronically may not be secure when it is transmitted to us. We recommend that you do not use unsecure channels to communicate sensitive or confidential information (such as your Social Security number or account number) to us.

Updating Your Information

Keeping your account information up-to-date is very important. You may review or update certain account information by logging in and accessing our Online Portal. If you cannot change the incorrect information online, or you prefer to request changes offline, please call us at 1-888-977-5228.

Changes to this Online Privacy Policy

We may change this Online Privacy Policy from time to time. When we do, we will let you know by appropriate means such as by posting the revised policy on this page with a new “Last Updated” date. Any changes to this Online Privacy Policy will become effective when posted unless indicated otherwise.

Last Updated: June 2022