Privacy Policy

Thank you for visiting AlphaClone LLC’s (“AlphaClone”) Internet web site (“Site”) located at the URL: http://alphaclone.com.

This Privacy Policy details certain policies implemented throughout AlphaClone governing AlphaClone’s use of personally identifiable information about users of our Site and services offered on or through the Site on this Site.

Privacy Policy Updates

Due to the Internet’s rapidly evolving nature, AlphaClone may need to update this Privacy Policy from time to time. If so, AlphaClone will post our updated Privacy Policy on the Site located at the following URL: http://alphaclone.com/privacy_policy.html and post notice of the change so it is visible when users log-on for the first time after the change is posted. AlphaClone encourages you to review this Privacy Policy regularly for any changes. Your continued use of the Site and/or continued provision of personally identifiable information to us will be subject to the terms of the then-current Privacy Policy.

Information Collection and Use

You can generally visit our Site without revealing any personally identifiable information about yourself. However, in certain sections of this Site and when you register to open an investment account with AlphaClone, when you sign up to access AlphaClone’s research service, contact us with questions or comments or request information, respond to surveys, questionnaires or contests, provide us with feedback, participate in chat or message boards, or complete a profile or registration form. Due to the nature of some of these activities, we may collect personally identifiable information such as your name, address, email address, phone number, age or date of birth, gender, user identification, password, social security number, driver’s license number, IP address, employment information, income level and personal financial information such as net worth, investment accounts and other contact information that you voluntarily transmit with your communication to us. If you sign up for our research service, we will be collecting some or all of the above information as well as you credit card payment information. Additionally, we may collect personally identifiable information about you that you provide to us when you contact us or that you voluntarily post in blogs, chat rooms, forums, message boards available from our Site and other users will be able to see any information that you post to such forums. We also may collect the foregoing personally identifiable information about you from our third party affiliate or partner companies and from marketing or advertising companies that provide us with such information as a part of their relationship with us. We also may collect information about you and your use of our Site, services and/or software through your use of our Site, services and/or software.

We may use your personally identifiable information to use our services, contact you to deliver certain services or information you have requested, verify your authority to enter our Site, improve the content and general administration of the Site and our services, provide you with notices regarding goods or services that you have purchased or may wish to purchase in the future, provide you with notices about other users of our Site, software and/or services that you may wish to contact and for targeted advertising.

You may opt out of receiving such communications from AlphaClone at any time (but not the transactional emails described in the paragraphs above) by contacting us as set out below in the section below entitled “Opting Out of Communications from AlphaClone.”

Accessing, Changing or Deleting your Information

We endeavor to ensure that your personal data is accurate by collecting it directly from you and providing you with the ability to update it.

If your personally identifiable information changes, or if you no longer desire our service, you may request us to correct, update, or delete your personally identifiable information or deactivate your account by making the change at our “Member Center”, which you can access by clicking the "Your Membership" link at the very top of every page.

Children’s Privacy

AlphaClone recognizes the privacy interests of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. This Site is not intended for children under the age of 13. AlphaClone does not target its services or this Site to children under 13. AlphaClone does not knowingly collect personally identifiable information from children under the age of 13.

Cookies

We may use small text files called cookies to improve overall Site experience. A cookie is a piece of data stored on the user’s hard drive containing information about the user. Cookies generally do not permit us to personally identify you.

Aggregate Information

The Site may track the total number of visitors to our Site, the number of visitors to each page of our Site, browser type, IP addresses, External Web Sites (defined below) linked to, and we may analyze this data for trends and statistics in the aggregate, but such information will be maintained, used and disclosed in aggregate form only and it will not contain personally identifiable information. We may use such aggregate information to analyze trends, administer the Site, track users’ movement, and gather broad demographic information for aggregate use.

Disclosure

We may provide your personally identifiable information and the data generated by cookies and the aggregate information to the vendors and service agencies that we may engage to assist us in providing our services to you. For example, we may provide your personally identifiable information to a credit card processing company to process your payment. We will disclose your personally identifiable information (i) when we reasonably believe we are required to do so by law, regulation or other government authority or when we deem it appropriate or necessary to provide such information to law enforcement authorities, (ii) to enforce the AlphaClone Terms of Use agreement, (iii) to protect and defend the rights or property of AlphaClone, or (iv) to protect the safety of our employees, agents, or users of our Site and our services. We will not sell or transfer your personally identifiable information to any company or organization, except that (i) we may transfer your personally identifiable information to a successor entity upon a merger, consolidation or other corporate reorganization or (ii) we may be required to transfer your personally identifiable information to partners or service providers that assist AlphaClone in managing investment accounts for our customers. Our partners service providers are contractually prohibited from using your information for any other purpose, including their own marketing purposes.

Links to Third Party Sites

The Site may provide links to other Web sites or resources over which AlphaClone does not have control (“External Web Sites”). Such links do not constitute an endorsement by AlphaClone of those External Web Sites. You acknowledge that AlphaClone is providing these links to you only as a convenience, and further agree that AlphaClone is not responsible for the content of such External Web Sites. Your use of External Web Sites is subject to the terms of use and privacy policies located on the linked to External Web Sites.

Opting Out of Communications from AlphaClone

Upon request, AlphaClone will allow any user to opt out of our monthly newsletter and from receiving emails about other products and services. You can contact us through our Help Center by email (contact@alphaclone.com), or follow the unsubscribe instructions included in each promotional email sent to you, including the newsletter.

Security

We may employ procedural and technological security measures that are reasonably designed to help protect your personally identifiable information from loss, unauthorized access, disclosure, alteration or destruction. AlphaClone may use firewalls, password protection, secure socket layer, and other security measures to help prevent unauthorized access to your personally identifiable information.

Use by Customers Only in United States

AlphaClone does not target its services or this Site to users outside the United States of America. AlphaClone does not knowingly collect personally identifiable information from users outside the United States of America.

Contact Us

If you have any questions or suggestions regarding our privacy policy, please contact us at:

Online Support: http://alphaclone.com/contact
Email: Privacy Inquiries: privacy@alphaclone.com
Press Inquiries: press@alphaclone.com
Mailing Address: One Market Street, Spear Tower, 36th Floor, San Francisco, CA 94105