Effective Date: July 25, 2019
We only collect information from you or about you that is reasonably necessary for us to provide the relevant product or Services, business relationship and/or communication, consistent with the nature of such product, service, relationship or communication. Based on the specific products, Services, business relationship or Sites involved as well as requirements under applicable law, we may collect the following categories of Personal Information from you or your representative:
Investment Manager Information:
When you contribute information to Vision Hill either through the use of the Site or directly in communication with Vision Hill, you will provide information related to your firm such as names of key personnel, addresses, emails, contact information, AUM, inception dates, strategy types, fund information, performance data, due diligence related information and other data.
User Contributions and Content:
All content added, created, uploaded, submitted, distributed, or posted to the Site by users (collectively “User Content”), whether publicly posted or privately submitted to Vision Hill directly is your sole responsibility and you consent to its accuracy and its use by Vision Hill to provide its products and Services. You may provide information or contribute content to be published or displayed on public or private areas of the Site and Services.
We may also collect any of the following information: name, email address, telephone number, mailing address, company name, title or position, business contact information, username and password, any other personal or company information you or your company or firm representative provides on our Site or Services or directly in communication with Vision Hill.
When you access and use the Site and Services, we may automatically collect certain details of your access to and use of the Site and Services, including traffic data, location data, logs and other communication data and the resources that you access and use on or through the Site and Services.
Neither the Site nor the Services is intended for children under 13 years of age, and we do not knowingly collect Personal Information from children under 13. None of our Sites or Services are targeted for use by children under 13. We do not target any of our products or Services or Site content/features for use by children under 13 years of age.
We use the information that we collect about you or that you provide to us, including any Personal Information, to:
Often due to the nature of the product or service involved or the context in which the Personal Information is used, it will be apparent how we intend to use the information. Additional information about processing related to a particular product or service may be separately posted on the relevant Site or contained in the applicable terms and conditions.
We may disclose aggregated information about our users, and information that does not identify any individual, company, or firm, without restriction, unless you have withdrawn such consent when providing us with the information.
From time to time, to the extent permitted by applicable law and subject to any contractual limitations on sharing Personal Information set forth in a relevant contract for products and Services, we may share your information with our affiliates, subsidiaries, business partners, clients (such as where we process your Personal Information in connection with your role with your employer), third party service providers and authorities in the following circumstances:
Affiliates, Subsidiaries, Business Partners and Clients. We may share your information with our affiliates, subsidiaries, business partners, and clients in the US and worldwide. To the extent required or permitted by applicable law, by visiting or using our Site or otherwise providing us with your information, you consent to this sharing of your information. Where such consent exists, to opt-out of such sharing, please contact us via email at firstname.lastname@example.org.
Service Providers. We may share your information with third parties who perform functions on our behalf (e.g., hosting or operating our Services or Sites, sending email marketing communications, or data analysis). We do not authorize these third parties to use your information for purposes other than for which it has been provided, and we do not authorize these third parties to disclose that information to unauthorized parties. We require these third parties to maintain appropriate security to protect your information from unauthorized access or processing.
As Required or Appropriate by Law. We may disclose your information to regulatory authorities, courts, and government agencies where we believe that doing so would be in accordance with or permitted or required by any applicable law, regulation or legal process, to defend the interests, rights, and/or property of Vision Hill, or to respond to emergencies.
Business Transfers. We may transfer your information to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, brands, affiliates, subsidiaries or other assets. To the extent permitted by applicable law, we may share information with a prospective buyer or transferee of the business as part of the diligence process provided that we require any such third party to maintain the confidentiality of your information and protect it with appropriate technical and organizational security measures.
We may share your information with other third parties as directed by you or subject to your consent. We may also share and otherwise process aggregated information or de-identified information that does not identify you individually with other third parties. We also use this aggregated or de-identified information for Vision Hill’s and its affiliates’ various business purposes, including the creation and sale of other products and services to our clients and potential clients. This aggregate or de-identified information is not traceable to any particular client or user and will not be used by a third party to contact you.
We do not share, sell, rent or trade the personal information you provide through our Site or directly to Vision Hill in private communications to our service providers or business partners for their own direct marketing purposes, unless we have explicitly given you the option to opt-in or opt-out of such disclosures. The foregoing restriction does not apply to information provided by those firms voluntarily contributing data for inclusion in our databases, indices, quarterly and monthly benchmark reports, and other data products. Any direct sharing of Personal Information, contact information, firm information and data, and performance or due diligence information will be considered as providing consent for Vision Hill to use such information and data for Vision Hill’s own purposes. Where such consent exists, to opt-out of such sharing, please contact us via email at email@example.com. For more information on data contribution, please reach out to us at the aforementioned email address.
To the extent required by applicable law, in our capacity as the controller of your Personal Information, we will also provide you with the opportunity to be informed of whether we are processing your Personal Information and at any time to access, correct, update, oppose, delete, block, limit or object to our use of your Personal Information. The foregoing rights will be afforded to you free of charge (except to the extent that your requests are manifestly unfounded or excessive, in which case, we may charge an administrative fee or refuse to meet your request). Please note that legal obligations that apply to our business may prevent us from immediately deleting parts of your information. To exercise your rights, please contact us as detailed below.
Access to your Personal Information. This means that you have the right to request information on our use of your Personal Information. You also have the right to request a copy of the Personal Information being processed at no cost. However, we may charge you a reasonable administrative fee to provide you with additional copies of the Personal Information. If you make your access request by electronic means such as email, we will provide you with the information in a commonly used electronic format.
Rectification of your Personal Information. We will at your request, or at our own initiative, rectify, anonymize, erase or complement Personal Information that you or we discover is inaccurate, incomplete or misleading. You also have the right to complete the Personal Information with additional data if relevant information is missing.
Erasure of your Personal Information. You have the right to request that we erase your Personal Information if we no longer have an acceptable reason for processing the data. Given this, erasure shall be made by us if:
However, there might be requirements under applicable law, or other compelling reasons, that prevents us from immediately erasing your Personal Information. In such case, we will stop using your Personal Information for any other reason than to comply with the applicable law, or the relevant compelling reason.
We have implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration and disclosure.
We take reasonable technical, administrative and physical security measures to protect your Personal Information, including applying generally accepted industry standards to protect the information submitted to us during transmission and once we receive it. However, no method of transmission over the internet, or method of electronic storage is 100% secure, so we unfortunately cannot guarantee absolute security.
The safety and security of your information also depends on you. Where we have given you (or where you have chosen) a password for access to certain parts of our Site or Services, you are responsible for keeping this password confidential. We ask you not to share your password with anyone. We urge you to be careful about giving out information in public areas of the Site or Services.
Unfortunately, the transmission of information via the internet and mobile platforms is not completely secure. Although we do our best to protect your Personal Information, we cannot guarantee the security of your Personal Information transmitted through our Site or Services. Any transmission of Personal Information is at your own risk. We are not responsible for circumvention of any privacy settings or security measures we provide. If you have reason to believe that your interaction with us is no longer secure (e.g., if you feel that the security of any account you might have with us has been compromised), please contact us immediately.
The technologies we use for automatic information collection may include:
Cookies (or mobile cookies). A cookie is a piece of data stored on a site visitor’s hard drive to help us improve your access to our site and identify repeat visitors to our site. For instance, when we use a cookie to identify you, you would not have to record your language preference more than once, thereby saving time while on our site. Cookies can also enable us to track and target the interests of our users to enhance the experience on our site. Usage of a cookie is in no way linked to any Personal Information information on our site.
Web Beacons. Pages of the Site and Services and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags and single-pixel gifs) that permit Vision Hill, for example, to count users who have visited those pages or opened an email and for other related Site and Services statistics.