This privacy policy (the “Online Privacy Policy”) describes the types of personal information 1RoundTable Partners, and/or its affiliates (collectively “1RT”) receives about you when you visit 1rtfund.com (the “Website”) and what we do with it, how we protect it, and how you can contact us if you have a question or concern about the personal information we hold about you. This Online Privacy Policy, including the rights referred below, shall apply only to individuals who visit the Website (and not to entities, to the extent those individuals represent those entities).
If you are an investor or potential investor in 1RT, you may also have access to the dedicated investor area of the Website (the “Investor Portal”). This Online Privacy Policy is in addition to Investor Privacy Notice on the Investor Portal.
Personal Information We Collect and How We Use It
When you visit the Website, we may collect the following personal information about you:
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Contact Information. For example, if you submit an inquiry via the “Contact” page we will have your name, email address, your city and state, and maybe (if you decide to include it) your phone number, as you submit it via the Contact Inquiry. In such instances, we will use such information to maintain our business records, manage our relationship with you, communicate with you, and comply with Law (defined below). We will not disclose such information to any outside party, other than as set out below.
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Website Usage Information. For example, we collect your IP address and other usage information via tracking technologies like cookies, for the purpose of monitoring access to the Website, understanding how you (and others) are using the website, to improve the website’s usability and security, and other internal processes.
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Investor Information. If you are a 1RT Investor and you choose to access the Investor Portal, we will also collect your email address to provide you with log in credentials and to allow you to access the Investor Portal.
We process such personal information about you based on our legitimate business interests as described above.
Disclosing Your Personal Information
To the extent we collect personal information about you via the methods described above, we do not disclose that personal information with any parties outside of our company other than as set out below. Specifically, we may share personal information with the following entities or under the following circumstances:
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Unaffiliated service providers (for example, Web hosting and e-mail service providers and other IT service providers, providers of professional advisory services, including consultants, legal advisors and accountants and other third party service providers);
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Government agencies, other regulatory bodies and law enforcement officials (for example, for tax purposes or for reporting suspicious transactions);
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Other organizations as permitted or required by law (for example for fraud prevention or to respond to a subpoena); and
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In connection with corporate business transactions, such as a merger or sale of a business.
For more information on how we use or disclose personal information we collect from users on the Investor Portal please refer to the Investor Privacy Notice.
How We Protect Personal Information Collected About You
We maintain operational policies, including physical, electronic and procedural protections, designed to safeguard and secure our data networks against unauthorized access to personal information we may collect through our Website, and have implemented policies designed to ensure that personal information we collect via our Website is used in compliance with this Online Privacy Policy.
Cookies and Other Tracking Technologies
1RT may use cookies and similar technologies (“cookies”) to support the operation of and maintain the Website and other digital offerings. A cookie is a small data text file which a website stores on your computer’s hard drive, if permitted by your web browser or app. We use cookies to identify you as a unique user when visiting our Website, to enable us to track usage so that we can improve the Website, for IT system security purposes and to help us in the ongoing maintenance of our Website.
Most browsers are initially set up to accept cookies. You can reset your browser to notify you when you have received a cookie, or alternatively, to refuse to accept cookies. However, you may not be able to use certain features on our website if you choose not to accept cookies. You can find more information about cookies and how to manage them at allaboutcookies.org. “Do not track” signals are preferences that users can set on their web browsers to limit how their activity is tracked across online services. The Website does not respond to “do not track” signals in your web browser.
We may collect analytics data or use third-party analytics tools such as Google Analytics to help us measure traffic and usage trends for our digital offerings and to understand more about the demographics of our users. You can learn more about Google’s practices with Google Analytics by visiting Google’s privacy policy. You can also view Google’s currently available opt-out options.
Third Party Websites
Our Website contains links to websites controlled and maintained by third parties, such as social media networks. We provide these links solely as a convenience for you. These features are recognizable by their third-party brand or logo and may collect your IP address and set a cookie to enable the feature to work properly. We do not have any control over the content of these websites, and we assume no liability or responsibility for such sites, the content contained therein, or the manner in which any information collected on such sites is used. This Online Privacy Policy does not govern the use of information collected on such third-party websites.
Children’s privacy
Our Website is not directed to individuals under the age of thirteen (13). 1RT does not intentionally collect information from individuals we know are under 13. Anybody under 13 should not provide personal information through our Website.
Changes to This Online Privacy Policy
We reserve the right to modify, amend, add to, replace or remove this Online Privacy Policy at any time. Any changes we may make to this Online Privacy Policy in the future will be posted on the Website.
Additional Information for California Residents
This section is provided for purposes related to the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”) and applies solely to the personal information that is subject to the CCPA. As used in this section, “personal information” means information that meets the definition of “personal information” as set forth in the CCPA and is not otherwise excluded from the scope of the CCPA.
Note that some or all of the personal information that 1RT collects or maintains is covered by one or more of the exemptions described below. As a result, in some cases, 1RT may have no obligation under the CCPA to accept any CCPA requests, and in other cases it may have no obligation to honor a particular CCPA request.
Your Rights Under the CCPA
The CCPA gives certain rights to California residents and imposes certain obligations on those businesses that are subject to the CCPA. As required by the CCPA, set forth below is a description of certain rights that California residents generally have under the CCPA.
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Right to Know. You have the right to request that we disclose to you the Personal Information we collect, use, or disclose, and information about our data practices.
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Right to Correct.You have the right to request that we correct inaccurate Personal Information that we maintain about you.
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Right to Request Deletion. You have the right to request that we delete your Personal Information that we have collected from you.
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Right to Non-Discrimination. We will not discriminate against you for exercising any of these rights.
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Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale or sharing of their personal information by the business.
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Right to Limit Use and Disclosure of Sensitive Personal Information. You have the right to limit the use or disclosure of sensitive personal information by the business.
We DO NOT sell your personal information for payment or for any other compensation.
Submitting a CCPA Request
If you wish to submit a CCPA request to 1RT, please contact us via the Contact form or via email at IR@1rtfund.com. You should generally expect to receive a response within 45 days of the date we receive your request. However, in some instances, we may require an additional 45 days to process your request in which case we will notify you and explain why the extension is necessary.
We will need to verify your identity before we can process your request. Through the request process, we will make you aware of any information that you will need to provide to us to process your request. You may have to confirm that you are a California resident and verify your identity or the identities of those authorized to submit requests on your behalf. Additionally, the information you provide will be used to help verify your identity.