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Assure Privacy Policy

Effective Date: August 1, 2019.


Assure Services, Inc. and its affiliates (“Assure”, “we” or “us”) are committed to protecting your privacy. Assure has developed this privacy policy to inform you how we collect, use, share, or otherwise process any information that is unique to you and may be used to identify you, or your usage data (“Personal Information”). It also describes the choices available to you regarding our use of your Personal Information and how you can update this information.

Why We Collect Information

To Provide Services: We perform various services for you and for third-parties that provide us with your information, including through our website https://assure.co and any of our other websites. The services include fund administration, compliance, tax, and other financial services. In many cases we need your Personal Information to perform these services. For example, if you invest in a special purpose vehicle (“SPV”), we need your Personal Information to properly administer that entity and provide you with important tax information.

To Personalize your Experience: We are always looking for ways to improve your experience with our Site. We may use your Personal Information and usage data to make your experience more personal and relevant. This may include sending you reminders and updates about services you have requested or may have interest in.

Information We Collect

Personal Data: name, username, date of birth, gender, marital status, title, social security number and/or tax identification number, home address, work address, billing address, email address, telephone numbers, professional history, password, picture, and copies of identification cards or other forms of identification. Financial Data: bank account information, money transfer instructions, funds transfer accounts, financial objectives, transaction history, salary, credit reports, investment documents, and financial statements.

How We Collect Information

We generally collect information by asking you to enter data into forms on our Site, by observing your activity on our Site and use of our services, from third-parties that have engaged us to provide services that require our collection of your Personal Information, or from documents uploaded directly by you or by a third-party from whom you have requested services, from third party information providers that provide background checks, verify your identity, creditworthiness, and your eligibility and suitability to participate in certain transactions or services.

We may also rely on your consent as a legal basis for using your Personal Information where we have expressly sought it for a specific purpose. If we do rely on your consent to a use of your Personal Information, you have the right to change your mind at any time (but this will not affect any processing that has already taken place).

Provide services and support: It is in our legitimate interest to market, sell and provide our services, respond to your service requests, including using the information to register you as a user and verify your identity or to contact you in order to discuss support, and the purchase of services. This also includes, for example, establishing your eligibility to invest on the Site under applicable laws, third-party contractual obligations and internal policies, providing tax and other investment related reporting for investors, and as otherwise needed to manage our business.

Cookies & Tracking Technologies

Assure uses cookies, web beacons and log files to automatically gather, analyze, and store technical information about Website visitors. This information includes the visitor’s IP address, browser type, ISP, referring page, operating system, date/time, and clickstream data (meaning data about the pages you visit on our Website). This information is used to improve Assure’s service and enhance the experience of Assure’s Website visitors. You can control the use of cookies at the individual browser level, but if you choose to disable cookies, it will limit your use of certain features or functions on our Website or service, affecting your Website experience.

How We Share Your Information

When performing its services, Assure may use third party sources to confirm or supplement the information that it obtains from you, including information about Individuals.

Assure never sells or provides personally identifiable information to third parties for uses apart from assisting Assure in servicing our customers and website visitors. When necessary, we may share your Personal Information with third parties including these categories of recipients:

  • • Service providers that support our services, such as software and services to store our customer information;
  • • Credit card and payment providers that help process payments for us (note that we do not store any provided credit card information); and
  • • Companies or individuals to whom you have granted access, such as investment managers, advisers, attorneys, accountants, administrators, or others as applicable.

Assure may share your information with law enforcement agencies, public authorities, or other organizations if legally required to do so, including to meet national security or law enforcement requirements, or if we have a good faith belief that such use is reasonably necessary to:

  • • comply with a legal obligation, process, or request;
  • • enforce our terms and conditions and other agreements, including investigation of any potential violation thereof;
  • • detect, prevent, or otherwise address security, fraud, or technical issues; or
  • • protect the rights, property, or safety of us, our users, a third party, or the public as required or permitted by law.
  • We may use and disclose aggregated or anonymized data and information for any purpose, such as analytics, marketing, or building reports.

Security

We take all necessary security and legal precautions to ensure the safety and integrity of the Individuals’ Personal Information that we receive from you, including, as appropriate, (i) the pseudonymization of Personal Information; (ii) ensuring the ongoing confidentiality, integrity, availability, and resilience of processing systems and services; (iii) restoring the availability and access to Personal Information in a timely manner in the event of a physical or technical incident; and (iv) regularly testing, assessing, and evaluating the effectiveness of technical and organizational measures for ensuring the security of the processing.

Unfortunately, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable standards to protect Personal Information, we cannot guarantee absolute security. If you have any questions about the security of your Personal Information, please contact us at the contact information listed below.

Where We Store Your Data

Assure has its company based in the United States and our Website is hosted in the United States. Therefore, if you are located outside the United States, the information that you submit to us through our Website will be transferred to the United States. Likewise, your data and your Personal Information will be accessible from and transferred to the United States.

Where you have a dispute or complaint regarding Assure’s collection, storage, or use of your Personal Information, you may make a complaint to Assure by sending it to privacy@assure.co. If you are an EU resident, where the dispute or complaint is not satisfactorily resolved or you don’t receive a timely response, you may escalate the matter to your European data protection authority free of charge, and Assure commits to cooperate with the relevant European data protection authority and will comply with the advice given by this authority with regard to your information which was transferred from the European Union in the context of this Website.

Individual Rights over Personal Information

Generally, you can review, cure inaccuracies, and update Personal Information through your account, if you have one, or by contacting privacy@assure.co. We may also access your account or profile and may make changes or adjustments as deemed appropriate by us. In certain circumstances, individuals also have the following rights:

  • • Access and portability: You have the right to know whether we process Personal Information about you, and if we do, to access data we hold about you and certain information about how we use it and who we share it with.
  • • Correction, erasure and restriction of processing: You have the right to require us to correct any Personal Information held about you that is inaccurate and have incomplete data completed or request we delete data: (i) where you believe it is no longer necessary for us to hold the Personal Information; (ii) where we are processing your data on the basis of our legitimate interest and you object to such processing; or (iii) if you believe the Personal Information we hold about you is being unlawfully processed by us. You can ask us to restrict processing data we hold about you other than for storage purposes if: (i) you believe the Personal Information is not accurate (whilst we verify accuracy); (ii) where we want to erase the Personal Information because the processing we are doing is unlawful, but you want us to continue to store; (iii) where we no longer need the Personal Information for the purposes of the processing, but you require us  to retain the data for the establishment, exercise, or defense of legal claims or where you have objected to us processing Personal Information and we are considering your objection.
  • • Objection: You have the right to object to our processing of data about you and we will consider your request. Please provide us with detail as to your reasoning so that we can assess whether there is a compelling overriding interest in us continuing to process such data or we need to process it in relation to legal claims.
  • • Complaints: In the event that you wish to make a complaint about how we process your Personal Information, please contact us and we will endeavor to deal with your request. If you are an EU resident, this is without prejudice to your right to launch a claim with the data protection supervisory authority in the EU country in which you live or work where you think we have infringed data protection laws.

You can exercise these rights by sending an email to privacy@assure.co or by mailing Assure at the address listed in this policy. Before we respond to your request, we will ask you to verify your identity. Note that these rights in their entirety only apply to EU residents and subject to the applicable law of the jurisdiction where you reside. Where exercise of a particular data subject's right is not required by law, your request will be handled on a case-by-case basis.

Applicability

Our website includes links to third party websites whose privacy practices may differ from those of Assure. If you submit Personal Information to any of those websites, your information is governed by their privacy policies. We encourage you to carefully read the privacy policies of those third-party websites before you submit any information to those websites.

Changes to This Privacy Policy

Each time you visit the Site or use our services, the current version of this Policy will apply. Please check the date of this Policy if you wish to view if changes have been made. You should check the Site regularly to be aware of changes. We encourage you to periodically review this page for the latest information on our privacy practices. Revisions to the privacy policy are effective immediately after being posted.

Contact

Please contact Assure with any questions or concerns about this privacy policy or our data collection practices:

Email:
privacy@assure.co

Address:
6510 S. Millrock Dr. Suite 400
Salt Lake City, UT 84121