Avestor Privacy Policy

Last updated on July 27th, 2022

Welcome to Avestor’s website (the “Site”). We refer to Avestor Inc. and our operating subsidiary, Avestor Partner Services, LLC., collectively as “Avestor”, “we” or “us”. This Site is operated by Avestor and has been created to provide information about our company and our asset management services (the “Services”).

Avestor Privacy Policy (the “policy”) describes the specific policies and procedures we use to collect, utilize, disclose, share and protect your Personal Information. Together with our Terms of Use, this Privacy Policy governs your use of our platform and services. By using the Site or Services, you consent to the data practices set forth in this Privacy Policy.

Avestor is committed to the protection of our visitors, registered users and clients (also referred to as “you” or “your”) privacy. We understand that keeping your information secure and confidential is critical to earning and keeping your trust.

Let us start by saying very clearly that we do not rent, sell or trade your Personal Information. Avestor’s core business is private fund management software and services.  Our business model is based on the amount of investor's assets under management by fund managers utilzing our platform. Maintaining confidentiality of the investor's data using our platform is a key part of our value proposition. We have no incentive to sell your information to others.

 

How to Use this Privacy Policy

This policy describes if and how your Personal Information is shared and/or disclosed, how we collect and use other information and how we address other privacy matters – such as deletion of your Personal Information upon request, and opting-out of marketing communications. Lastly, we describe methods for contacting Avestor if you have privacy questions, comments or feedback.

Transparency is one of the best ways to earn your trust. The information we collect from you increases as your relationship with us grows. The progression of that relationship is shown in the figure below. Additional information of what we collect is presented in the How We Collect & Use Your Information section of this privacy policy.

 

How We Collect & Use Your Information

“Personal Information” means your personally-identifiable information such as your name, email or mailing address, phone number, account credentials (user id and passwords), social security number, government ID numbers and other information that can be used to identify you personally.

We also collect and use other information that we obtain from your activities using our services. This includes information that you do not explicitly provide to us but which may be implicitly provided to us as part of such activities. More information on this is provided below.

 

The following describes in further detail the information we collect at various stages of our relationship with you:

The below table explains what we are collecting and if it can be limited.

What User information do we share & with whom?

 

The below table outlines what information we may share and why with our partners.

California

California Consumer Privacy Act Privacy Statement (“CCPA Statement”)

This CCPA Statement is provided pursuant to the California Consumer Privacy Act (“CCPA”) and applies to California residents and supplements our overall Statement with additional disclosures and rights.

Your rights under CCPA

As of January 1, 2020, California law permits residents of California to request certain details about how their personal information is shared with third-parties or affiliated companies for direct marketing purposes.

California residents may also take advantage of the following rights:

  • You may request, up to two times each year, that we disclose to you the categories and specific pieces of personal information that we have collected about you, the categories of sources from which your personal information is collected, the business or commercial purpose for collecting your personal information, the categories of personal information that we disclosed for a business purpose, any categories of personal information about you that we sold, the categories of third-parties with whom we have shared your personal information, and the business or commercial purpose for selling your personal information, if applicable.

  • You may request that we delete any personal information that we have collected from or about you. As described in more detail in our Statement, there are some reasons we will not be able to fully address your deletion request, such as if we need to complete a transaction for you, to detect and protect against fraudulent and illegal activity, to exercise our rights, or to comply with a legal obligation.

To take advantage of your disclosure and deletion rights, please contact us at aupport@avestorinc.com. We may need to verify your identity to enable us to process your request. We value your privacy and will not discriminate in response to your exercise of privacy rights. We will respond to your request within 45 days of receipt of your request, after proper verification, unless we need additional time, in which case we will let you know.

Links to Other Web Sites

This Privacy Policy applies only to Avestor. Our Site or Services may contain links to other web sites not operated or controlled by us. The policies and procedures we described here do not apply to the Third Party Sites. The links from the Services do not imply that Company endorses or has reviewed the Third Party Sites. We suggest contacting those sites directly for information on their privacy policies.

Additional Privacy Information

How to Request Deletion of the Personal Information We Collect

Avestor allows you to delete your registered account if you are not a client. If you are a client or were previously a client, we must maintain your account to deliver required statements and tax related information to you. To delete your account, please email us at support@avestorinc.com.

Opt-out Information

If you request to be added to our Opt-out lists, we will keep your Personal Information on those Opt-out lists until you request to be removed from such lists. We allow you to Opt-out of the following:

  • Marketing emails – send your request to support@avestorinc.com to be added to the opt-out list.

  • Physical Mailings - send your request to support@avestorinc.com to be added to the opt-out list.

  • Advisory phone calls - notify your advisor at the time of the call that you prefer no proactive phone calls and will reach out to Avestor when required.

 

Email Records

 

Avestor keeps business records, including emails you send to us, for up to five (5) years after you close your account and all funds are distributed to you to meet our regulatory compliance requirements. This includes any email you send to our privacy, security or support teams.

Children and Minors

Avestor does not knowingly collect Personal Data from minors under the age of 18. If you are under the age of 18, please do not submit any Personal Data through the Services. We encourage parents and legal guardians to monitor their children’s Internet usage and to help enforce our Privacy Policy by instructing their children never to provide Personal Data on the Services without their permission. If you have reason to believe that a minor under the age of 18 has provided Personal Data to Avestor through the Services, please contact us, and we will endeavor to delete that information from our databases.

Modifications to our Privacy Policy

Our business may change from time to time. As a result, at times it may be necessary for Avestor to make changes to our Privacy Policy. We reserve the right to update or modify this Privacy Policy at any time and from time to time without prior notice. Please review this policy periodically, and especially before you provide any Personal Data. This Privacy Policy was last updated on the date indicated above. Your continued use of the Services after any changes or revisions to this Privacy Policy shall indicate your agreement with the terms of such revised Privacy Policy.

 

Privacy Questions, Comments or Feedback?

Please contact us at support@avestorinc.com