In the course of serving our clients, Accrete may obtain personal information about such clients. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately. This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “Accrete” refers to Accrete Management LLC and its affiliates.
THE SOURCES OF INFORMATION
The personal information we collect about you comes primarily from the account applications or other forms and materials you submit to Accrete during the course of your relationship with us. We may also collect information about your transactions and experiences with Accrete relating to the services Accrete provides. In addition, depending on the services you require, Accrete may obtain additional information about you, such as your credit history, from consumer reporting agencies. Finally, in the provision of financial services to you and subject to strict compliance with all applicable laws and regulations, information may be collected about you indirectly from monitoring or other means (e.g. e-mail monitoring). In these circumstances, the information is not accessed on a continuous or routine basis, but it may be used for compliance or security purposes.
THE INFORMATION WE HAVE ABOUT YOU
If you deal with Accrete in your individual capacity (e.g. as a private client), or as a settlor/trustee/beneficiary of a trust, or as an owner or principal of a company or other investment vehicle established to invest on your behalf or on behalf of your family, etc., the typical information we collect about you may include (in addition to any other information as may be determined on a case-by-case basis): Your full name, phone number, email address, organization, and other contact details; Extensive financial information, including source of wealth, investment experience and objectives, risk tolerance and, in certain jurisdictions, representations required under applicable law or regulation concerning your financial resources; and A personal identifier such as, depending on your country of residence, your Social Security Number, National Insurance Number, Tax File Number, etc. Of course, you are not required to supply any of the personal information that we may request. However, failure to do so may result in our being unable to open or maintain your account or to provide services to you. While we make every effort to ensure that all information we hold about our clients is accurate, complete and up to date, we rely on our clients promptly notifying us if there are any changes to their personal information.
OUR USE OF YOUR PERSONAL INFORMATION
PRIVACY AND THE INTERNET
The following additional information will be of interest to you as a visitor to this site: Users of Accrete.com are required to identify and authenticate themselves prior to accessing our services. Generally, identification and authentication take place through the use of your user name and a password. Accrete.com is built upon a secure infrastructure with multiple layers of protection. Accrete uses industry standard encryption technologies to protect your information from external compromise. Security is a cooperative effort between Accrete and the users of Accrete.com. Please remember that your login and password are personal to you and should not be made available to any other person. Also, you should discontinue their use and notify us if you have any reason to suspect that someone else may be using them. We may collect certain aggregate and non-personal information when you visit the Accrete.com. We may collect this information through “cookie” technology. Cookies are bits of text that can be placed on your computer’s hard drive when you visit certain websites. Cookies may enhance your online experience by saving your preferences while you are visiting a particular website. The “help” portion of the toolbar on most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. Remember, though, without cookies, you may not be able to take full advantage of all of the Accrete.com features. “Clickstream” data (e.g., information regarding which of our Web pages you access, the frequency of such access, and your product and service preferences) may be collected by Accrete itself, or by our service providers, using cookies, Web beacons, page tags, or similar tools that are set when you visit our Web site or when you view an advertisement we have placed on another Web site. Clickstream data and similar information may be shared internally within Accrete and used: for administrative purposes; to assess the usage, value and performance of our online products and services; to improve your experience with our Web sites; and as otherwise permitted by applicable law or regulation. If you are a Accrete client, this information helps us suggest products or service offerings that may be of interest to you. This information may be processed by us for the purposes described above, or on our behalf by third parties, solely in accordance with our instructions. Accrete may make available on this Web site third party applications such as content linking or sharing facilities. Information collected by providers of such applications is governed by their privacy policies. Our Web sites are not currently configured to respond to “do not track” signals or similar mechanisms. Information For EEA Users (EU plus Iceland, Norway and Liechtenstein)
WHAT RIGHTS DO I HAVE?
Where Accrete is a Controller of data under the EU’s new General Data Protection Regulation (GDPR), individuals located in the European Economic Area (EEA) will have additional rights with respect to their non-public personal information (NPI), including the right of access, rectification, restriction, opposition, erasure and data portability (each, as defined by the GDPR). Where possible, we obtain and rely on user consent as a lawful basis for processing personal data. In some cases, Accrete may process and retain NPI pursuant to a legal obligation or another legitimate interest under the GDPR to protect your vital interests, the interests of Accrete, or those of another person. How May I Exercise My Individual Rights? Users located within the EEA may contact our Data Protection Officer with questions or requests regarding their NPI using the contact information below. Please note that Accrete may request additional information from you to verify your identity before we disclose any personal or account information. You may opt out of receiving promotional communications at any time by following the “unsubscribe” instructions found within Accrete email updates or changing your contact preferences. Please note, you will continue to receive essential account-related information, even if you unsubscribe from promotional emails. Who Can I Contact at Accrete Regarding Data Protection Issues? Accrete has designated a Data Protection Officer to assist with data privacy and data protection issues. You may contact him/her by emailing email@example.com and addressing your questions or concerns to the Data Protection Officer. Other Privacy Policies or Statements; Changes to Policy; Contact This policy provides a general statement of the ways in which Accrete protects your personal information. You may, however, in connection with specific products or services offered by Accrete, be provided with privacy policies or statements that supplement this policy. This policy may be changed from time to time to reflect changes in our practices concerning the collection and use of personal information. The revised policy will be effective immediately upon posting to our Web site. This version of the Policy is effective May 24, 2018. If you require further information regarding our privacy policies and practices please contact admin@Accrete.com.
STATEMENT ON COOKIES
COOKIES AT ACCRETE AND HOW WE USE THEM