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.
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.
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).
D. CATEGORY: Commercial information
EXAMPLE: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
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.
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.
G. CATEGORY: Geolocation data
EXAMPLE: Physical location or movements.
H. CATEGORY: Sensory data
EXAMPLE: Audio, electronic, visual, thermal, olfactory, or similar information.
I. CATEGORY: Professional or employment-related information
EXAMPLE: Current or past job history or performance evaluations.
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.
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.
We obtain the categories of personal information listed above from the following categories of sources:
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:
Personal information does not include:
II. USE OF PERSONAL INFORMATION
We may use or disclose the personal information we collect for one or more of the following business purposes:
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:
(2) tax authorities:
(3) our lawyers, auditors and other professional advisors for purposes of:
We may share Personal Information for purposes including the following:
(1) The processing is necessary for the performance of a contract, for example:
(2) In pursuance of our legitimate interests, or those of a third party to whom your personal data are disclosed, for example:
(3) The processing is necessary for compliance with applicable legal or regulatory obligations, for example:
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.
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.
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