Privacy And Cookies

1. Introduction

This Privacy and Cookies Policy (“Policy”) describes how AcrePoint Capital and its affiliates (collectively, "AcrePoint Capital," "we," "us," or "our") collect, use, and disclose information about you. This Policy applies to information we collect when you access or use our websites (including [YourCompanyWebsite.com], and any other sites or applications that link to this Policy), and in connection with our and our portfolio companies’ business activities, including in-person or virtual events and other commercial contexts (collectively, the “Services”).

We may provide different or additional notices of our privacy practices for certain products, services, or activities. If you are a current or former employee, contractor, or job applicant, please refer to the privacy notice you received during your application or onboarding process.

We may change this Policy from time to time. If we make changes, we will notify you by revising the date at the top of this policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification). We encourage you to review the Policy whenever you access the Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

2. Collection of Information

Information You Provide to Us We collect information you provide directly to us. For example, we collect information when you create an account, fill out a form, make an investment, request customer support, or otherwise communicate with us. The types of information we may collect include your name, email address, postal address, phone number, financial information related to your investments, and any other information you choose to provide.

In some cases, we may be required by law to collect certain information about you. We will inform you at the time of collection whether this information is mandatory.

Information We Collect Automatically When You Use the Services When you access or use our Services, we automatically collect certain information, including:

  • Log and Usage Information: We collect information related to your access to and use of the Services, such as your IP address, browser type, operating system, pages viewed, links clicked, and the page you visited before navigating to our Services.

  • Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use tracking technologies, such as cookies and web beacons, to collect information about you. Cookies are small data files stored on your hard drive or in device memory that help us improve our Services and your experience, see which areas and features of our Services are popular, and count visits. Web beacons (or "pixels") are electronic images that may be used in our Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see the “Cookies” section below.

Information We Collect from Other Sources We may also obtain information from other sources. For example, we may collect information about you from third parties, including but not limited to mailing list providers, publicly available sources, and our portfolio companies. Additionally, if you create or log into your account through a social media site, we will have access to certain information from that site, such as your name and account information, in accordance with the authorization procedures determined by such social media site.

3. Use of Information

We use the information we collect to administer your account, process your investments and provide the Services you request. We also use your information to:

  • Provide, maintain, and improve our Services;

  • Send you technical notices, updates, security alerts, and support and administrative messages;

  • Respond to your comments, questions, and customer service requests;

  • Communicate with you about products, services, and events offered by AcrePoint Capital and others, and provide news and information we think will be of interest to you;

  • Monitor and analyze trends, usage, and activities in connection with our Services;

  • Detect, investigate, and prevent fraudulent transactions and other illegal activities and protect the rights and property of AcrePoint Capital and others;

  • Personalize your online experience and the advertisements you see on other platforms based on your preferences, interests, and Browse behavior; and

  • Carry out any other purpose described to you at the time the information was collected.

4. Sharing of Information

We may share information about you as follows or as otherwise described in this Policy:

  • With vendors, service providers, and consultants that perform services for us, such as companies that assist us with web hosting, data analysis, and marketing;

  • With our portfolio companies in connection with our and their business activities;

  • In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process;

  • If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of AcrePoint Capital or others;

  • In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company;

  • Between and among AcrePoint Capital and our current and future parents, affiliates, subsidiaries, and other companies under common control and ownership; and

  • With your consent or at your direction.

We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

5. Cookies

Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Services. For more details about the cookies we use, please see our Cookie Declaration [Note: You would need a cookie scanning tool to generate a specific, dynamic cookie declaration list for your site].

6. Advertising and Analytics Services Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the web and in mobile applications. These entities may use cookies, web beacons, and other technologies to collect information about your use of the Services and other websites and applications, including your IP address, web browser, mobile network information, pages viewed, time spent on pages or in apps, links clicked, and conversion information. This information may be used by AcrePoint Capital and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites, and better understand your online activity.

7. Security

AcrePoint Capital takes reasonable measures to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration, and destruction.

8. Your Choices

Account Information You may update certain account information you provide to us by logging into your account. If you wish to delete or deactivate your account, please email us at [privacy@YourCompanyWebsite.com], but note that we may retain certain information as required by law or for legitimate business purposes.

Promotional Communications You may opt out of receiving promotional emails from AcrePoint Capital by following the instructions in those emails. If you opt out, we may still send you non-promotional communications, such as those about your account or our ongoing business relations.

9. Jurisdictional-Specific Notices

For Individuals in the EEA, UK, and Switzerland If you are in the European Economic Area (EEA), the United Kingdom, or Switzerland, you have certain rights and protections under the law regarding the processing of your personal data.

  • Legal Basis for Processing: When we process your personal data, we will only do so in the following situations:

    • As necessary to perform our responsibilities under our contract with you.

    • When we have a legitimate interest in processing your personal data, such as to communicate with you about our services, which is not overridden by your data protection interests.

    • When you have given us your consent to do so.

    • When it is necessary for compliance with a legal obligation.

  • Data Subject Requests: You have the right to access personal data we hold about you and to ask that your personal data be corrected, erased, or transferred. You may also have the right to object to, or request that we restrict, certain processing. If you would like to exercise any of these rights, you may contact us as indicated below.

  • Data Transfers: We transfer personal data to the United States and other countries that may not have the same level of data protection as your home jurisdiction. We provide adequate protection for the transfer of personal data in accordance with applicable law, such as by obtaining your consent, relying on the European Commission’s adequacy decisions, or executing Standard Contractual Clauses.

  • Questions or Complaints: If you have a concern about our processing of personal data that we are not able to resolve, you have the right to lodge a complaint with the Data Protection Authority where you reside.

For Individuals in California The California Consumer Privacy Act or “CCPA” provides consumers with specific rights regarding their personal information. If you are a California resident, 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.

  • Request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions.

  • Not receive discriminatory treatment by us for the exercise of your privacy rights.