Effective Date November 1, 2019
ParkSlope Capital LLC (“ParkSlope”, “we”, “us” or “our”) is committed to protecting your privacy on its website (the “Site”). The Site is a website which includes an investor portal website maintained by ParkSlope at www.parkslopecap.com. Your privacy is important to us. Accordingly, we have developed this policy so you may understand how we collect, use, communicate, disclose and make use of your Personal Information (defined below).
Personal Information we collect may include:
- Personal Information you provide in connection with your investment in one of the ParkSlope funds, such as your name, address, e-mail address, phone number, social security number, tax ID number, payment information and details, bank account details, photograph(s), financial information including assets, income, investment objectives, financial situation and debt. This information is obtained (or may be obtained) in writing, in person, by telephone, electronically or by any other means;
- Personal Information which may be obtained by our affiliates for the purpose of tax reporting to you and to the various agencies to which we report as required by law, including disclosures on various Internal Revenue Service (“IRS”) forms
- Your login credentials and password details;
- Information gathered from any background check about you;
- A record of your participation in transactions and fulfillment, your activities and any other details captured about you as you use the Site;
- Electronic information such as internet protocol addresses which identify your device on the internet (“IP address”), browser type, internet service provider (“ISP”), referring/exit pages, operating system, date/time stamp, and clickstream data;
- Communications you send us in the form of queries or comments
- Information that relates to your account balance, capital contributions, redemptions and distributions, and any other transactions concerning which we investment management services;
- Information from non-affiliated third parties pursuant to law, rules, regulations, standard securities industry practice and/or legal process, including information and/or documents received, shared, produced or provided in connection with a subpoena, discovery request or other legal process compelling production; and
- Information from non-affiliated third parties related to servicing your account for purposes of providing investment management services
We will use your information in the following ways:
- Before or after the time of collecting information, we will identify the purposes for which the Personal Information is being collected;
- We will collect and use your Personal Information solely to fulfill the purposes specified by us and for other purposes consistent with those purposes, unless we obtain the consent of the individual concerned or as may be required by applicable law;
- We retain your Personal Information only as long as necessary consistent with the purpose or as may be required by applicable law or by our document retention policies;
- We will collect your Personal Information by lawful and fair means and, where appropriate, with your prior knowledge or consent;
- Personal Information submitted by you should be relevant for the purposes for which it is to be used and, to the extent necessary for these purposes, should be accurate, complete and up to date;
- We will endeavor to protect your information by reasonable security safeguards against loss or theft as well as unauthorized access, disclosure, copying, use or modification; and
- We will endeavor to make readily available to you as a user of the Site, information about our policies and practices relating to the management of Personal Information.
We are committed to conducting our business in accordance with these principles with a view to ensuring that the confidentiality of your Personal Information is protected and maintained.
When you visit the Site, in order to be able to provide you with better experience we may automatically collect additional information such as the type of internet browser or mobile device you use, your IP address and the operating system of your device which is automatically recognized by our web server.
We will only use and disclose your Personal Information to comply with applicable law and regulation and to administer our management of your accounts with us and the funds which we manage including, from time to time, disclosing your Personal Information to fund managers, accountants, custodians, auditors, agents or contractors that work on our behalf and assist us in providing and supporting the services we provide including, without limitation, processing transactions, settlement, clearing, transferring, reconciling, collection, processing subscriptions and capital calls, processing distributions and other payments, fulfilling requests, performing background and OFAC checks and AML due diligence, analyzing data, and tax reporting
- as required or necessary to carry out fully and properly our business such as:
a. disclosures to affiliated and non-affiliated third-party service providers who supply us with computer-related services including data maintenance, document processing and delivery, and online-facilitated investing; and
b. processing services, and disclosures to affiliated and non-affiliated third parties such custodians, administrators, accountants, auditors, legal firms, online platforms that facilitate investing, etc.;
- to persons assessing our compliance with industry standards (e.g., professional licensing authorities, etc.);
- for purposes of making you aware of future investment opportunities available through our affiliates.
We may access, preserve and share your Personal Information in response to a legal request (such as a search warrant, court order or subpoena) if we have a good faith belief that applicable law requires us to do so. We may also access, preserve and share information, including Personal Information, when we have a good faith belief it is necessary to detect, prevent and address fraud and other abusive, inappropriate or illegal activity and to protect ourselves, you and others, including as part of investigations, whether in the U.S. or international. For example, we may provide information, including Personal Information, to our third-party servicers about the reliability of your account to prevent fraud and abuse. Personal Information we receive from you or about you, including data related to your transactions with ParkSlope, may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation (U.S. or foreign), or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm or abuse. We also may retain Personal Information from accounts that have been disabled for violations of our terms for an indefinite period of time, to prevent repeat abuse or other violations of our terms.
When You Can Limit Sharing
Federal law gives you the right to limit the sharing of your Personal Information, when: (1) sharing is for the everyday business purposes of affiliates, or (2) sharing your Personal Information with affiliates or non-affiliates is for the purpose of marketing to you. We do not share your information in any of these ways, except for purposes of making you aware of future investment opportunities available through our affiliates and to the extent an affiliated service provider requires such information to manage your account and investment in our funds. State laws and individual companies may give you additional rights to limit sharing.
Investors cannot opt out of allowing ParkSlope to share their Personal Information with third parties (whether or not affiliated) when doing so is necessary to service their accounts. Investors may opt out of our sharing information with affiliates for purposes of making you aware of future investment opportunities available through those affiliates by informing ParkSlope in writing that you have elected to opt out by e-mailing such request to compliance@ParkSlopeCap.com.
Maintenance of Records
Your Personal Information will be maintained during the time you are an investor, and for the required time thereafter that such records are required to be maintained by federal and state securities laws. After this required period of record retention, all such information will be destroyed.
Links to Third-Party Sites
We reserve the right, subject to applicable law, to use and disclose any de-identified information at our discretion. For example, we may provide anonymized information to third parties that process Personal Information to generate related analytical information (“Analytics Processors”). The Analytics Processors do not have any independent right to use your Personal Information except to provide such services to us in generating such anonymous information and related analytics, all on an aggregated, de-identifiable and anonymized basis.
ParkSlope follows commercially reasonable physical, electronic, and managerial procedures to safeguard and secure your nonpublic personal information. However, no company, can fully eliminate security risks associated with Personal Information. Among the security measures taken is a login process requiring a password and username that you select and a firewall protecting our hosting server, as well as active system monitoring, penetration testing, and data encryption. We will retain your password and username as part of your Personal Information, but will not share this information with anyone. Please be advised that you are responsible for keeping your password and user name confidential and secure from unauthorized persons. We will endeavor to inform you as soon as reasonably practicable if we become aware of a data breach.
Please remember to close your browser at the end of your online session to help ensure that others are unable to access your Personal Information, especially if you use a shared or a publicly visible computer. It is your responsibility to protect the access to your account from whichever computer or mobile device you are using by logging out of your account each time you complete a session.
Data Storage and Data Protection Compliance
Your data will be processed and held by us in New York, New York USA and, as such, it may be subject to U.S. laws and accessible by the U.S. government, tribunals, law enforcement and regulatory agencies. The level of data protection established in the U.S. is lower than that within the European Union. We will take measures to ensure that your Personal Information is stored safely with us. We take care to comply with various U.S. data-protection acts (including the Gramm-Leach-Bliley Act) and the applicable data-protection acts in other relevant jurisdictions.