4PINES FUND SERVICES
PRIVACY POLICY
LAST UPDATED: June 1, 2022
This Privacy Policy (“Policy”) discloses the privacy practices for 4Pines Financial Services (“4Pines”). The Policy describes 4Pines’ permissible use, collection, disclosure of Data (as defined below). By using 4Pines’ Website and services, you consent to the use, collection, and disclosure of your Data in accordance with this Policy.
4Pines is committed to the principles of respecting your privacy, keeping your Data safe and keeping the decision as to how your information is used, collected and disclosed in your hands. Therefore, our privacy pledge is:
· 4Pines only collects Data that is of legitimate interest to 4Pines, which means Data that is useful and necessary for improving our products and services, and your experience.
· 4Pines will maintain fairness and transparency at all times with regards to how we collect and process Data.
· 4Pines never sells your Data, and only shares your Data when required by applicable law or when given your explicit consent to do so for a specific reason.
· 4Pines makes decisions based solely on automated processing or profiling of Data.
· 4Pines takes the security of your Data seriously.
Use of Data
We use the Data to provide the services and information you request; to enhance, improve, operate, and maintain our services, our programs, websites and other systems; to prevent the fraudulent use of our services and other systems; to prevent or take action against activities that are, or may be, in violation of this Policy or applicable law; to tailor advertisements, content, and other aspects of your experience on and in connection with the services; to maintain a record of our dealings with you; for other administrative purposes; and for any other purposes that we may disclose to you at the point at which we request your Data and pursuant to your consent.
We will not share your Data with any third party, other than when you consent or as necessary under applicable laws. 4Pines may transfer Data, including identification, commercial and geopolitical information, to third parties, where authorized by a Client under the agreement between 4Pines and said Client
4Pines has a policy not to sell any Data and it has not sold any Data in the last 12 months.
Data Retention
The Data will be retained for as long as is required by applicable laws or as required for the purposes for which it was collected. When the latter of these end and without unreasonable delay, 4Pines will proceed to erase all Data held in its systems.
Security
We take precautions to protect your Data. While we use encryption to protect Data transmitted online, we also protect your Data offline. Only employees who need the Data to perform a specific job are granted access. The computers and servers in which we store Data are kept in a secure environment.
Email Marketing and Unsubscribing If you are subscribed to one of 4Pines’s marketing emails like our newsletter, we may occasionally send you relevant updates. When we send our marketing emails, we may use web beacons, customized links, or similar technologies to determine whether the e-mail has been opened and on which links you click. This way, we are better able to provide you focused e-mail communications or other information in the future.
You can stop the delivery of marketing emails from 4Pines at any time by unsubscribing. We include a link at the bottom of every marketing email which you can utilize to update your preferences by selecting and deselecting lists based on your personal interests, or you can unsubscribe from all marketing communications. Alternatively, you can make a direct request to unsubscribe by emailing the following address: info@4Pinesfs.com.
Automated Profiling
4Pines does not carry out automated profiling and will not make any decisions based on the automated processing of data.
Definition of Data
Subject to applicable laws, 4Pines may process information that serves a legitimate interest to 4Pines (“Data”). This Data may include what is known generally as personally identifiable information, or “Personal Data” under GDPR, DPL or CCPA (See applicable section below). Among other uses, we will use your Data to respond to you regarding the reason you contacted us, and to deliver the services you have requested.
See below for categories of Data we may collect, accompanied by descriptions and examples of each category:
– Personal Identifiers: This includes names, previous names, addresses, email addresses, account user names, social media profiles, telephone numbers, publicly available photographic images and signatures;
– Device and Online Identifiers and Related Information: This includes online identifiers, internet protocol addresses, mobile/wireless carriers and other device information;
– Background Information: This includes date of birth, family information, personal and professional associates and associations, and any other information we are required to collect by law;
– Financial Information: This includes credit report information, credit scores, bank account numbers, transaction information (both from your accounts with us and any accounts you link to a 4Pines service), financial account information (including statements and checks) used to validate your identity, account information about externally linked accounts, account login credentials you use to access our services, household income data, tax documents, your authority over financial accounts, including trusted contact/beneficial interest in and other information about entities you are associated with, public company affiliations, available account balance information, source of wealth information, investment goals and experience, net worth and liquidity needs, income and other financial information;
– Government Identifiers: This includes Social Security number, Tax Identification Number, national identification number, other government-issued identification number, driver’s or operator’s license number, passport number and copies of government IDs;
– Protected Classification Characteristics: This includes age, national origin, citizenship, nationality, race, ethnicity, religious or philosophical beliefs, health, marital status, and veteran or military status. Please note that we do not collect information regarding gender identity, gender expression, or sexual orientation unless you provide it to us in connection with servicing your account; and
– Professional or Employment-Related Information: This includes occupation, title, employer, employment history, income, industry affiliations and education.
Please note that, by freely providing 4Pines with any unsolicited Data, subject to the relevant laws, you are consenting for 4Pines to use the Data in conformity with this Policy.
4Pines may process Data from the following categories of individuals:
· Website Visitors and Users. Data from visitors and/or users of 4Pines’ website.
· Connected Persons of 4Pines’ Clients. Data from an individual or entity connected with the individual or entity who entered into an agreement with 4Pines for the provision of services (“Client”) in one of the following ways:
o Connected person controls a Client through ownership or vested executive powers or authority;
o Connected person is employed by or acts as an agent or representative, either directly or indirectly of a Client;
o Connected person is employed by or acts as an agent or representative, either directly or indirectly, of a service provider of a Client and 4Pines interacts with them in connection with its provision of services to a Client; or
o Connected person is not in one of the above categories, but they interact with 4Pines in connection with 4Pines’ provision of the services to a Client.
· Investors and Connected Persons of Investors. You are an investor of a Client or you are connected with such an investor of a Client in the following ways:
o You control an investor through ownership or vested executive powers or authority;
o You are employed by or act as an agent or representative, either directly or indirectly, of an investor;
o You are employed by or act as an agent or representative, either directly or indirectly, of a service provider of an investor and 4Pines interacts with you at the investor’s instruction; or
o You are not in one of the above categories, but you interact with 4Pines in connection with an investor’s investment in a Client.
General Data Protection Regulation (GDPR):
The below relates specifically to 4Pines’ processing of Personal Data (as defined below) of natural persons who reside in the European Union or the United Kingdom, and provides additional information required under both the EU General Data Protection Regulation 2016/679 (“EU GDPR”) and the Retained Regulation (EU) 2016/679 (individually the “UK GDPR” and collectively with the EU GDPR, the “GDPR”). Under GDPR, Personal Data means information that permits an individual to be identified directly or indirectly. What Are EU/UK Data Subject’s Rights with Respect to Personal Data?
· Right to Be Informed. Data Subjects1 have the right to be informed about Personal Data 4Pines collects and how this data is used.
· Right to Access and Portability. Data Subjects have the right to obtain a confirmation whether 4Pines is processing their Personal Data and to obtain copies of their Personal Data or to request that 4Pines forward such copies to another person.
· Right to Rectification. Data Subjects have the right to make a request to correct any inaccuracy or incompleteness of their Personal Data.
· Right to Erasure. Data Subjects have the right to make a request to delete their Personal Data.
· Right to Restrict Processing. Data Subjects have the right to ask us to restrict the processing of their Personal Data for a period when the accuracy of the data is verified, or if they think that the processing is unwarranted.
· Right to Object. Data Subjects have a right to object to processing of their Personal Data in certain circumstances, such as when the data is used for marketing.
· Right to Withdraw Consent. If a Data Subject has given consent to the processing of Personal Data, the Data Subject has the right to withdraw the consent at any time.
· Right to Lodge a Complaint. Data Subjects have a right to lodge a complaint with a supervisory authority if they consider that the processing of Personal Data infringes GDPR. For residents of the UK, the appropriate supervisory authority is the Information Commissioner’s Office. For residents of the EU, the appropriate contact is the supervisory authority in the EU state of their residence, place of work or place of the alleged infringement.
The rights enumerated above are subject to certain conditions and exemptions. Where such conditions or exemptions apply, 4Pines has a right not to comply with the request. Additionally, while in most circumstances requests based on the above listed rights shall be fulfilled free of charge, 4Pines is allowed and may charge fees to fulfill the request.
Cayman Islands
The below relates specifically to 4Pines’ processing of Personal Data (as defined below) of natural persons who reside in the Cayman Islands, and provides additional information required under The Data Protection Law, 2017 (Law 33 of 2017) (“DPL”). Under DPL, Personal Data must be obtained only for one or more specified lawful purposes and must not be further processed in any manner incompatible with that purpose or those purposes.
What Are Cayman Islands Data Subject’s Rights with Respect to Personal Data?
– Right to Be Informed. Data Subjects have the right to be informed of the identity of the organization processing their Personal Data, and about the purposes for processing the Personal Data.
– Right to Access. Upon making a subject access request in writing, Data Subjects have the right to obtain a confirmation whether their Personal Data is being processed, a copy of their Personal Data, and other supplemental information which is contained in this Policy.
– Right to Rectification. Data Subjects have the right to make a request to correct any inaccuracy or incompleteness of their Personal Data.
– Right to Cease or Restrict Processing. Data Subjects have the right to request to cease processing, or not to begin processing, or to cease processing for a specified purpose or in a specified manner, the Data Subject’s Personal Data.
– Rights Related to Processing by Automatic Means. Data Subjects have the right to request that a decision which significantly affects him or her is not made solely by the processing by automatic means of Personal Data.
– Rights Related to Direct Marketing. Data Subjects have the right to request that processing of their Personal Data for the purpose of direct marketing cease, or not begin.
– Right to Rectification, Blocking, Erasure, and Destruction. Data Subjects have the right to seek from the Cayman Office of the Ombudsman an order for rectification, blocking, erasure or destruction of inaccurate Personal Data and opinions based on such.
– Right to Compensation. Data Subjects have the right to seek compensation for damages caused by contravention of the DPL.
– Right to Complain to Ombudsman. Data Subjects have the right to complain to the Office of the Ombudsman about any perceived violation of the DPL.
The rights enumerated above are subject to certain conditions and exemptions. Where such conditions or exemptions apply, 4Pines has the right not to comply with the request. Additionally, while in most circumstances requests based on the above listed rights shall be fulfilled free of charge, 4Pines is allowed and may charge fees to fulfill the request under certain circumstances.
Residents of California
This section specifically relates to 4Pines’ processing of Personal Data (as defined below) from individuals who reside in California and provides additional information relevant under the California Consumer Privacy Act of 2018 (Cal. Civ. Code §§1798.100 et seq) (“CCPA”). Under the CCPA, Personal Data is defined as “information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.”
What Are California Data Subject’s Rights with Respect to Personal Data?
– Right to Access and Portability. Data Subjects have the right to request the information about the categories of Personal Data being collected and the purposes for which the Personal Data is being collected, as well as the categories of the sources from which the Personal Data is collected, the categories of third parties with whom the business shares Personal Data, and the specific pieces of Personal Data that was collected. Data Subjects have the right to obtain copies of their Personal Data in a readily useable format that allows the consumer to transmit this information from one entity to another entity without hindrance.
– Right to be Forgotten. Data Subjects have a right to make a request to delete Personal Data.
– Non-Discrimination. 4Pines may not discriminate against a Data Subject because the Data Subject exercises any of the rights under the CCPA. 4Pines will not deny Data Subjects services, charge different prices or rates for services, or provide a different level or quality of service in retaliation for exercising CCPA rights.
– Right to Opt Out. Data Subjects have the right to request that a business that sells Personal Data about the Data Subject to third parties not sell the Data Subject’s Personal Data.
The rights enumerated above are subject to certain conditions and exemptions. Where such conditions or exemptions apply, we have a right not to comply with the request. Additionally, while in most circumstances requests based on the above listed rights shall be fulfilled free of charge, 4Pines is allowed and may charge reasonable fees to fulfill the request.
Updates
We may occasionally update this Policy. When we do, we will also revise the “last updated” date at the beginning of the Policy. Your continued use of our services after such changes will be subject to the then-current policy. If we change this Policy in a manner that is materially less restrictive of our use or disclosure of your Data, we will use reasonable efforts to notify you of the change and to obtain your consent prior to applying the change to any Data that we collected from you prior to the date the change becomes effective. We encourage you to periodically review this Policy to stay informed about how we use, collect and disclose Data.
CONTACTING US
If you have any questions or comments about this Policy, please contact us using the following contact information: info@4Pinesfs.com.