Privacy Policy.
Last updated August 2024
Financial institutions like Invest Agile Limited and our affiliates and subsidiaries (collectively “Invest Agile,” “we,” or “us”) may be required to provide privacy policy notices when we hold personal information relating to individuals, as defined below (“Personal Information”).
Non-Identifiable Data: When you interact with Invest Agile through our website, we receive and store certain personally non-identifiable information. We may store such information itself or such information may be included in databases owned and maintained by Invest Agile’s affiliates, agents, or service providers. We may use such information and pool it with other information to track, for example, the total number of visitors to our website, the number of visitors to each page of our website, and the domain names of our visitors’ Internet service providers.
In operating our website, we may use a technology called “cookies.” A cookie is a piece of information that the computer that hosts our Services gives to your browser when you access our website. Our cookies help provide additional functionality to the website and help us analyze usage more accurately. For instance, our website may set a cookie on your browser that allows you to access our website without needing to remember and then enter a password more than once during a visit to our website. On most web browsers, you will find a “help” section on the toolbar. Please refer to this section for information on how to receive notification when you are receiving a new cookie and how to turn cookies off. We recommend that you leave cookies turned on because they allow you to take advantage of some of the website features.
Aggregated Personal Information: In an ongoing effort to better understand and serve the users of the website, we may conduct research on its customer demographics, interests, and behavior based on the Personal Information and other information provided to us. This research may be compiled and analyzed on an aggregated and/or de-identified basis, and we may share this aggregated and/or de-identified data with its affiliates, agents, and business partners. We may also disclose aggregated and/or de-identified user statistics and other metrics related to our website in order to describe our products or services to current and prospective business partners and to other third parties for other lawful purposes.
Analytics and Tracking Technologies: We may, and we may allow third-party service providers to, use cookies (as noted above) or other tracking technologies to collect information about your browsing activities over time and across different websites following your use of our website. For example, we use Google Analytics, a web analytics service provided by Google, Inc. (“Google”). Google Analytics uses cookies to help us analyze how users use the website and enhance your experience when you use the website. For more information on how Google uses this data, go to www.google.com/policies/privacy/partners.
Our website currently does not respond to “Do Not Track” (DNT) signals and operates as described in this Privacy Policy whether or not a DNT signal is received. If we do so in the future, we will describe how we do so in this Privacy Policy.
We believe that protecting the privacy of Personal Information is of the utmost importance. It is our policy to safeguard the privacy, confidentiality, and security of Personal Information and to comply with the applicable data protection laws, including SEC Regulation S-P and state regulations pertaining to Personal Information. It is also our policy to process Personal Information in accordance with the General Data Protection Regulation 2016/679 (the “GDPR”) where applicable. We process Personal Information lawfully, fairly, and in a transparent manner in relation to you and ensure that the Personal Information which we process is relevant, accurate, and limited to what is necessary in relation to the purposes for which it is processed, and that Personal Information is kept confidential. We have in place appropriate technical and organizational measures to ensure security of Personal Information, including protections against unauthorized access, use, disclosure, acquisition, destruction, or alteration, misuse, damage, or accidental loss.
By voluntarily providing us with Personal Information, you are consenting to our use of it in accordance with this Privacy Policy. If you provide Personal Information on our website, you acknowledge and agree that such Personal Information may be transferred from your current location to the offices and servers of Invest Agile and the authorized third parties referred to herein located in the United States.
In compliance with applicable laws, this notice is to provide you with information about Personal Information we process, the rights you can exercise with regard to Personal Information we process, the periods for which Personal Information will be stored, and the persons and entities with which we may share Personal Information.
Personal Information is information about you that makes you personally identifiable. This includes, without limitation, your name, contact information such as your address, e-mail address, and phone number, date and place of birth, gender, country, as well as your social security number, assets, income, investment experience, or any other identifying information you may send us in your interactions with us. We may also collect business information such as your job function and title, department, organization name, and location.
If you are an investor or prospective investor, we collect Personal Information about you from the following sources:
- Information we receive from you on fund subscription documents and related forms;
- Information we receive from you when you make an additional subscription;
- Information you provide to us in general correspondence with us;
- Information you provide to us as part of any onboarding or due diligence process;
- Information we receive when you make transactions with us or our affiliates (for example, account activity and balances);
- Publicly available information we may find;
- Information we receive from third parties (for example, from an individual who introduces you to us); and
- To a limited extent, information we receive when you provide your contact details via our website.
If you are an investor, we will process your Personal Information for one or more of the following purposes and on the following legal grounds:
- To perform services on behalf of Invest Agile funds or to take steps at your request prior to entering into a contract with you, such as to provide requested information about our services, to facilitate the opening of your account with us, and for the management and administration of your holdings on an ongoing basis to the extent that doing so is necessary, including, without limitation, the processing of redemptions, conversions, transfers, additional subscription requests, the payment of distributions, and to keep you updated in relation to your investments;
- To carry out anti-money laundering checks and related actions which we consider appropriate to meet any legal, regulatory, or judicial obligations imposed on us or in relation to the processing of data in the public interest or in pursuit of our legitimate interests in relation to the prevention of fraud, money laundering, terrorist financing, bribery, corruption, tax evasion, and to prevent the provision of financial and other services to persons who may be subject to economic or trade sanctions, on an ongoing basis, in accordance with our and (if applicable) Third Parties’ (as defined below) anti-money laundering procedures;
- To report tax-related information to tax authorities in order to comply with any legal, regulatory, or judicial obligations;
- To engage in, monitor, and record telephone calls and electronic communications for our legitimate interest of: (i) processing and verification of instructions; (ii) investigation and fraud prevention purposes; (iii) crime detection, prevention, investigation, and prosecution; (iv) enforcing or defending us and our affiliates, ourselves, or through Third Parties to whom we may delegate such responsibilities or rights in order to comply with any legal, regulatory, or judicial obligation imposed on us; or (v) where the processing is in the public interest;
- To disclose information to Third Parties (as defined below) and parties such as other service providers to us, regulatory authorities, and technology providers in order to pursue our legitimate interest to comply with any legal or regulatory obligation, court order, or judicial request imposed on us;
- To engage in, monitor, and record telephone calls for quality, business analysis, training, and related purposes in order to pursue our legitimate interests to improve service delivery;
- To pursue our legitimate interest of improving our services to you, providing you with investment services and information relating to investment services, making our procedures more efficient, or implementing security measures;
- To update and maintain records and fee calculations to meet legal, regulatory, or judicial obligations and to retain anti-money laundering and other records.
We do not disclose any Personal Information we collect, as described above, about our current or former investors to anyone other than to administrators, custodians, banks, and service providers (including but not limited to our IT service providers, email archivists, and CRM system providers) in connection with the administration, processing, and servicing of customer accounts or to our accountants, attorneys, and auditors (all such persons, collectively, “Third Parties”), or otherwise as required by law.
If you are not an investor, we collect Personal Information about you on the following occasions:
- When you use our services;
- When you register to attend an event;
- When you apply for a job with us;
- When you propose an investment to us;
- When we retain you as a service provider or you solicit us to do so; or
- When you otherwise communicate with us or contact us via our website.
In this case, we will process your Personal Information for one or more of the following purposes and on the following legal grounds:
- To provide information you request about us and our services; as is necessary to take steps at your request prior to entering into a contract with you;
- To evaluate investments or services you propose to provide to us and to communicate with you regarding such investments or services; as is necessary to take steps at your request prior to entering into a contract with you;
- To provide communications (such as publications, educational materials) to you relating to products and services you are interested in;
- To provide information about our events;
