We know that while you as investors (i.e., “you”) are entrusting us to manage your money, you are also entrusting us with the privacy and security of your personal information. We take that trust seriously.
If you are a resident of the European Union and wish to use our site, you can find information on the data policies of 1623capital.com that pertain to you by clicking here.
1. The Information we collect about you
We will collect and process the following personal data from you:
1.1 Information you give us:
This is information about you that you give us directly when you interact with us.
Signing Up for Content Delivered via Email: When you sign up for a report or other content delivered by email, we will ask for your email address. We may also ask for your name and other information as well as capture your IP address.
Becoming an Investor: When becoming a Limited Partner or Investor in one of our Funds, we need to know the sort of information typically used for financial transactions, such as your name, address, telephone number, and banking information. Our partners encrypt all of this information using Transport Layer Security (TLS), the replacement for the deprecated Secure Socket Layers (SSL) technology.
Other Services: We may also ask for additional information when providing other services. If you don’t want to give us the information requested, you certainly don’t have to, but you will not be able to take advantage of such offerings. On occasion, we may also ask you for other personal information in connection with surveys, contests or other promotional offers running on our site, but again, your participation in these features is purely voluntary.
1.2 Information we collect about you from using our site:
While on our site, we automatically log certain information about how you’re using our site. This information may include the URL that you just came from, your IP address (or a partially anonymized IP address) and the pages you visit while on our site.
We may place a pixel on pages on our site, or those of our advertisers and partners. This enables us to record in our server logs that a specific user ID has visited a particular page. This data allows us to analyze and determine our audience’s behavioral characteristics, which helps us to optimize our site and marketing focus.
1.3 Information we receive from other sources:
We allow our partners to collect certain information when you visit our site. They may utilize cookies, pixels, beacons, or other technologies to collect and use information about you during your visit to this and other websites. We have also engaged third-party companies to process information about our users on our behalf, to help us improve our sites and find new members. These companies will combine our data about how you visit our websites with information that they have collected from outside our sites and provide it to us (and only us) so that we can optimize your experience on 1623capital.com across devices and based on your interests.
To learn more about this behavioral advertising, including information on how to opt-out, please visit the Google Analytics opt-out program to learn how to opt out of having your information collected in browsers for ad serving purposes.
Additionally, 1623 Capital has contracted with a third-party firm, Verify Investor, to manage the investor qualification process. Verify Investor will verify a prospective investor’s accredited status by either requesting and reviewing the relevant forms (credit check, tax returns, etc.) or by having an attorney, accountant, or financial advisor submit a letter certifying the Accredited Investor status. This investor information will not be shared with 1623 Capital LLC or any other party, except for the determination of eligibility for investment in products offered by 1623 Capital.
In addition, 1623 Capital has contracted with a third-party firm, SS&C Technologies, to provide fund administration services, which includes generating the financial statements for each Limited Partner as well as any tax statement preparation. SS&C Technologies will also assist in the money transfer associated with investor commitments and associated capital calls, thus SS&C Technologies may both provide 1623 Capital with information and receive information from 1623 Capital.
2. The legal bases we rely on:
We can collect and process your data with your consent.
For example, if you have given your consent to receiving marketing material from us at the point we collected your information.
2.2 Contractual obligations
We need your personal data to comply with our contractual obligations.
- For example, where you have provided us with your email address to receive our services, we will use this information in order to effectively deliver and communicate our services.
2.3 Legal compliance
If the law requires us to, we may need to collect and process your data.
For example, we can pass on details of people involved in fraud or other criminal activity affecting us to applicable law enforcement.
2.4 Legitimate interest
We may require your data to pursue our legitimate interests in a way which might reasonably be expected as part of running our business and which does not materially impact your rights, freedom or interests.
- For example, it is in our legitimate interests to ensure that content from our site is presented in the most effective manner for you and your computer and we provide you with the information, products and services that you request from us.
3. How we use your information
We will use this information in our legitimate interests, where we have considered these are not overridden by your rights:
- To administer our site and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- To keep our site safe and secure;
- For measuring or understanding the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- To keep you informed about products and services similar to the ones you invest in;
- To improve our site to ensure that content is presented in the most effective manner for you and for your computer;
- To allow you to participate in interactive features of our service, when you choose to do so; and
- Internal research: Cookies (which are discussed further below) and the other information we automatically track are used to help us better understand how our audience uses our site as well as for internal research on users’ demographics and interests.
4. Our promotional updates and communications
Where permitted by one of the legal bases above, we will use your personal information for marketing analysis and to provide you with promotional update communications by email about our products/services and those of our business partners.
You can object to further marketing at any time by: selecting the “unsubscribe” link at the end of all our marketing and promotional update communications to you; or (iii) sending us an email to [email protected].
Please note: If you become a Limited Partner or for any other reason register for an account with us, we may contact you to confirm your partnership, investment status, or registration, or to provide you with information about its terms or features. You may wish to keep these transactional or relationship emails, to help you use our products and services. If you unsubscribe from our emails you may not receive these transactional notifications.
5. How long we keep your information
We retain personal data for as long as necessary to fulfil any legal obligations we may have as well as for purposes of processing your information (for example, if you become a Limited Partner, we will need your information to keep in contact with you). We may also retain aggregate information beyond this time for research purposes and to help us develop and improve our services. You cannot be identified from aggregate information retained or used for these purposes.
6. Cookies and other technologies
Cookies contain bits of data that websites such as ours place on your computer’s hard drive for record-keeping purposes. Cookies can make the web more useful by collecting and storing information about your preferences on a particular site and help websites operate more efficiently. Cookies and similar technologies enable you to be remembered when using that computer or device to interact with websites and online services and can be used to manage a range of features and content as well as storing searches and presenting personalized content.
We use our cookies:
With the aim of optimizing our website and improving member experience. Cookies help us estimate our audience size, determine usage patterns and help us better target content and ads based on our users’ interests.
You have the option of not accepting the cookies we set. However, if you reject our cookies, you will not be able to take advantage of most of the features on our site, including subscription-based services.
7.2 In addition to the cookies set directly by our partners, there are also cookies set by third parties to help deliver and monitor their ads. Please note we neither control nor have access to those cookies, and these advertisers’ uses of cookies are subject to their own privacy policies and not that of 1623 Capital.
8. Cookie Removal and More Information
8.1 You can always modify your browser so as not to accept cookies or to notify you when cookies are sent to it. For more information about cookies including removing any or all of your cookies, please visit http://www.allaboutcookies.org.
8.2 Also, if you would like to remove Google Analytics, please go to http://tools.google.com/dlpage/gaoptout. You should be aware that this will affect your Google cookies on all sites, and not just ours.
9. Information Sharing and Disclosure
9.1 We do not give, rent, lend or sell individual information to any third party, except for the purposes listed above. Furthermore, we will not disclose any information about individual users, except as described below.
a) With your consent.
b) Third Party Service Providers: We may employ the services of third party providers to aid us in certain aspects of our operations (such as the distribution of our email or our administrator for the Fund(s)). Depending on the services performed, some of these providers may be provided with user information. These contractors would be subject to confidentiality agreements which limit their use and disclosure of all information they obtain through their relationship with us to 1623-related business only, consistent with this policy.
c) Legal Requests: We may disclose your personally identifiable information to protect the rights and property of 1623 as well as to comply with any applicable law or valid legal process. This includes, but is not limited to:
i. Requests by Government Agencies. We will disclose any information we have in our possession to law enforcement or government officials in response to any inquiry or investigation or if in our sole discretion, we believe it is necessary or appropriate in connection with any investigation or activity that is or may be illegal or may expose us or you to legal liability.
ii. Disclosures we are legally required or entitled to make under any enactment, rule of law or by the order of a court.
We are committed to protecting your personal information. All information that you provide to us is stored on our secure servers. While we do our best to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us, and you do so at your own risk.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorized access.
Our site may, from time to time, contain links to external sites. We are not responsible for the privacy policies or the content of such sites.
11. Changing Your Information or Closing Your Account
If you would rather not hear from us by email, please click the unsubscribe link, which you will find at the bottom of our email messages.
If you want to close your account – i.e., so that it cannot be logged into – please contact us at [email protected].
12. Users Aged 13 or Under
Protecting the safety of children when they use the internet is important to us.
The site is intended for use only by persons who are at least 13 years of age. By using this site, you confirm to us that you meet this requirement. If you are aged 13 or under, please get your parent/guardian’s permission beforehand whenever you provide personal information to our website. Users without this consent are not allowed to provide us with personal information.
13. Changes to This Privacy and Cookie Statement
We may amend this Privacy and Cookie Statement from time to time. If we make any substantive changes to this policy, we’ll announce it on our site and notify you by email.
14. European Users
For the purposes of European Economic Area data protection law, (the “Data Protection Law”), the data controller is: 1623 Capital LLC, 2000 Duke Street, Suite 275, Alexandria, VA 22314, USA ([email protected]).
Below you’ll find the types of cookies that we set when you visit 1623capital.com and their purpose. To help you better understand why we’re setting them, we’ve used the categories and definitions set by the International Chamber of Commerce (“ICC”):
Strictly Necessary: cookies that enable the services that you have specifically asked or paid for;
Performance: cookies that collect information on how visitors use our site including the pages visited and most frequented as well as the sources of our traffic. They are used to help us improve how the site works;
Functionality: cookies that help us remember the choices you have made so we can provide you with a more personalized experience; and
Advertising: cookies used to deliver more relevant ads, and to make sure you don’t see the same adverts over and over again.
If you have any questions about the cookies we set, please contact our Data Protection Officer at [email protected]
14.2 Data Storage: The data that we collect from you is transferred to, and may be stored at, a destination outside the European Economic Area (“EEA”) that is not subject to equivalent Data Protection Law. For our purposes, the information we collect is processed and stored in the US.
We may transfer your personal information outside the EEA:
- In order to store it;
- In order to enable us to provide goods or services to you and fulfil our contract with you. This includes order fulfilment, processing of payment details, and the provision of support services;
- Where we are legally required to do so; and
- In order to facilitate the operation of our group of businesses, where it is in our legitimate interests and we have concluded these are not overridden by your rights.
14.3 European site users have certain rights under certain circumstances:
- to be provided with a copy of your personal data held by us;
- to request the rectification or erasure of your personal data held by us;
- to request that we restrict the processing of your personal data (while we verify or investigate your concerns with this information, for example);
- to object to the further processing of your personal data, including the right to object to marketing (as mentioned in ‘our promotional updates and communications’ section); and
- to request that your provided personal data be moved to a third party.
14.4 Your right to withdraw consent:
- Where the processing of your personal information by us is based on consent, you have the right to withdraw that consent without detriment at any time by contacting us at [email protected]. You can also change your marketing preferences at any time as described in ‘our promotional updates and communications’ section.
14.5 You can also exercise the rights listed above at any time by contacting us at [email protected].
If your request or concern is not satisfactorily resolved by us, you may approach your local data protection authority, (see http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.html).
Data Protection Officer
1623 Capital LLC
2000 Duke Street, Suite 275
Alexandria, VA 22314
Last Updated: March 19, 2019