Distributary Privacy Policy

1. OBJECTIVE

This document describes how we collect, share and protect personal information from clients. You have the right to tell us how you would like to control some aspects of this, but there is a minimum amount of information that we must use and share in order to provide advisory services.

2. PERSONAL INFORMATION WE COLLECT ABOUT YOU

We may collect the following information about our customers firm, its individual users within the firm as well as information about its clients, including but not limited to:

  • Tax identification number
  • Date of birth
  • Individual and legal entity name
  • Address and telephone number
  • Account balance and detailed transaction information
  • Investment experience and asset performance data
  • Financial goals, net worth and information about expenses and liabilities

3. OTHER INFORMATION WE COLLECT

Distributary collects data about our customers, and potentially their clients, activity on the website, including but not limited to:

  • Users geolocation
  • Time of usage and events within the application
  • Hardware or software used in the interaction with the web application
  • User activity, screen resolution and system performance

We collect this data through browsers, "Cookies" & Web Beacons, and users are encouraged to read more about how these tools work here (https://allaboutcookies.org/) and here (https://allaboutcookies.org/what-is-a-web-beacon).

3. HOW DO WE USE YOUR PERSONAL AND OTHER INFORMATION

We collect personal and other information for the specific purpose of providing various services to you, including but not limited to:

  • Extracting data, providing reporting, monitoring and maintaining financial interests.
  • To tailor content and information that we believe may be valuable to you
  • For research purposes
  • To better understand how clients use our services alongside applications required for that service

Information we collect is only available to employees who require access to perform their duties and provide specific products or services to the specific customer. All employees are trained regarding security awareness to safeguard all customer information. Training topics include but are not limited to managing social engineering, passwords, data handling, procedures and secure management of computer hardware. All of our internal functions are only made available through virtual private networks which are logged and auditable.

Customers should be aware that we may be required to share information in certain additional scenarios:

  • We may be required by law to respond to court orders and legal investigations.
  • We may be required to transfer information in the event of a change of ownership, at which point we would notify you in advance
  • We may aggregate and anonymize information for the benefit of all of our clients
  • With third parties where we have business relationships. If we provide personally identifiable customer information, we insist that the third party keeps the same level of confidentiality and takes consistent approaches to limiting access to data to employees only when required

4. HOW SECURE IS MY INFORMATION

We have implemented commercially reasonable precautions, including, where appropriate, password protection, encryption and SSL to protect sites and applications and the information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

All of our affiliates have privacy policies which we believe are appropriate, but we ask that you read and confirm your comfort level with our partners and affiliates. Please be aware that despite our best efforts, no data security measures can guarantee 100% security all of the time.

You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a password that nobody else knows or can easily guess and keeping your password private.

Should you choose to share your log-in information with others, we would recommend that you retain a list of individuals or entities who have this information and we can not be responsible for any lost, stolen, or compromised passwords or for any activity on your account via third party or unauthorized password activity.

How long do we keep your personal data

Distributary maintains your information, to the extent required by the law, for a period which is reasonably required to resolve legal, regulatory, tax or other retention requirements. Failing these requirements, you may request to have your data permanently deleted, at which point we will initiate a request subject to our cloud storage providers policies.

5. CAN I ACCESS AND MODIFY MY PERSONAL INFORMATION

You may modify any account information that you have submitted, by logging into your account and updating your information. Please note that copies of information that you have updated, modified or deleted may continue to reside in our systems for a limited period of time.

6. WHAT CHOICES DO I HAVE

Some data, such as account information, financial transactions and balances, email addresses and documents uploaded are required for us to fulfill our services. The nature of our service means that opting out of sharing certain data with us, or limiting our use in specific ways, may result in our inability to provide our product or service. In some scenarios, this may require termination of part or all of existing Professional Services Agreements.

7. HOW TO CONTACT US ABOUT PRIVACY

If you have any questions about the privacy of your information and how our services work, or would like to make a complaint, please contact us at security@distributary.io