Privacy Policy

Access Management Company LLC (collectively, the “Company,” “we,” or “us”) wants you to be familiar with how we collect, use and disclose information.  This Privacy Policy describes our practices in connection with information that we collect through:

• Website operated by us located at https://accessinvestments.com/ from which you are accessing this Privacy Policy (the “Website”)
• Software application made available by us for use on or through computers and mobile devices (the “App”)
• Our social media pages located at https://www.linkedin.com/company/accessinvestments/, https://twitter.com/access_invest, https://www.facebook.com/accessinvestments, https://www.instagram.com/accessinvestments/ (collectively, our “Social Media Pages”)
• HTML-formatted email messages that we send to you that link to this Privacy Policy or other communications with you
• Offline business interactions you have with us.

Collectively, we refer to the Websites, App, Social Media Pages, emails, offline business interactions as the “Services.”

Personal Information

“Personal Information” is information that identifies you as an individual or relates to an identifiable individual.  The Services collect Personal Information, including:  

• Name
• Address
• Telephone number
• Email address
• Date of birth
• Citizenship or residency status
• Country of birth
• Employment information, such as title and role
• Financial and investment information, including bank account information
• Information about your transactions with us or others, including information and choices concerning your current investments and tax-related information
• Information we receive from you or (if difference) the investor on application or other forms, such as Social Security number, tax identification number, passport, or any similar number or other government-issued ID
• Online account information, such as username and password
• IP address
• Profile picture
• Contacts
• Social media account ID

Collection of Personal Information

We and our service providers collect Personal Information in a variety of ways, including:

• Through the Services.

• • We collect Personal Information through the Services, for example, when you register an account to access the Services, sign up for a newsletter, participate in an investment transaction, attend one of our events, or contact us.

• From Other Sources.

• • We receive your Personal Information from other sources, for example:
  • publicly available databases or registers;
  • tax authorities;
  • governmental agencies and supervisory authorities;
  • credit agencies; and
  • fraud prevention and detection agencies.
• If you connect your Google account to your Services account, you will share certain Personal Information from your Google account with us, for example, your name, email address, photo, list of Google contacts, and any other information that may be or you make accessible to us when you connect your Google account to your Services account.

We need to collect Personal Information in order to provide the requested Services to you.  If you do not provide the information requested, we may not be able to provide the Services. If you disclose any Personal Information relating to other people to us or to our service providers in connection with the Services, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

Use of Personal Information

We and our service providers use Personal Information for the following purposes:

• Providing the functionality of the Services and fulfilling your requests.

• • To provide the Services’ functionality to you, such as arranging access to your registered account, and providing you with related benefits or customer service.
  • To respond to your inquiries and fulfill your requests, when you contact us via one of our online contact forms or otherwise, for example, when you send us questions, or when you request information about our Services.
  • To complete your transactions, verify your information, and provide you with related benefits, special promotions, or customer service.
  • To send administrative information to you, such as changes to our terms, conditions, and policies.

• Providing you with our newsletter and other marketing materials and regular performance updates.

• • To send you marketing related emails and newsletters, with information about our Services, new products and other news and updates about our Company.

• Analyzing Personal Information for business reporting and providing personalized services.

• • To analyze or predict our users’ preferences in order to prepare aggregated trend reports on how our digital content is used, so we can improve our Services.
  • To better understand your interests and preferences, so that we can personalize our interactions with you and provide you with information and/or offers tailored to your interests.
  • To better understand your preferences so that we can deliver content via our Services that we believe will be relevant and interesting to you.

• Aggregating and/or anonymizing Personal Information.

• • We may aggregate and/or anonymize Personal Information so that it will no longer be considered Personal Information. We do so to generate other data for our use, which we may use and disclose for any purpose, as it no longer identifies you or any other individual.

• Accomplishing our business purposes.

• • For general business administration, including communicating with investors, service providers and counterparties.
  • For business activities relating to the Company, such as investor relations, discussions with the Company’s service providers and counterparties, decision-making in relation to partnership, and business strategy, development and marketing.
  • For data analysis, for example, to improve the efficiency of our Services;
  • For accountancy and audits, to verify that our internal processes function as intended and to address legal, regulatory, or contractual requirements;
  • For fraud prevention and fraud security monitoring purposes, for example, to detect and prevent cyberattacks or attempts to commit identity theft;
  • For administration of IT systems and monitoring;
  • For developing new products and services;
  • For enhancing, improving, repairing, maintaining, or modifying our current products and services, as well as undertaking quality and safety assurance measures;
  • For identifying usage trends, for example, understanding which parts of our Services are of most interest to users;
  • For determining the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users; and
  • For operating and expanding our business activities, for example, understanding which parts of our Services are of most interest to our users so we can focus our energies on meeting our users’ interests.

Disclosure of Personal Information  

We disclose Personal Information:

• To our third party service providers, to facilitate services they provide to us.
  • These can include providers of services such as website hosting, data analysis, banking and payment processing, order fulfillment, return authorization, fraud prevention, information technology and related infrastructure provision, customer service or related benefits, email delivery, auditing, and other services.
• By using the Services, you may elect to disclose Personal Information.
  • Through your Google sharing activity. When you connect your Services account to your Google account, you may be able to share information with the contacts associated with your Google account and with Google. By doing so, you authorize us to facilitate this sharing of information, and you understand that the use of shared information will be governed by Google’s privacy policy.
• By connecting your UMB account with our Services, you will share information with us, and we will share Personal Information with UMB, which they will process in accordance with UMB’s Privacy Notice and Online Privacy Notice.

Other Uses and Disclosures

We may also use and disclose Personal Information as we believe to be necessary or appropriate: (a) to comply with applicable law, to respond to requests from public and government authorities, to cooperate with law enforcement, or for other legal reasons; (b) to enforce our terms and conditions; and (c) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others. We may use, disclose or 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 assets or stock (including in connection with any bankruptcy or similar proceedings).

OTHER Information

“Other Information” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Services collect Other Information such as:

• Browser and device information
• App usage data
• Information collected through cookies, pixel tags and other technologies
• Demographic information and other information provided by you that does not reveal your specific identity
• Information that has been aggregated in a manner such that it no longer reveals your specific identity

We and our service providers may collect Other Information in a variety of ways, including:

• Your browser or device.
  • Certain information is collected by most browsers or automatically through your device, such as your Media Access Control (MAC) address, computer type (Windows or Mac), screen resolution, operating system name and version, device manufacturer and model, language, Internet browser type and version and the name and version of the Services (such as the App) you are using. We use this information to ensure that the Services function properly.
• Your use of the App.
  • When you download and use the App, we and our service providers may track and collect App usage data, such as the date and time the App on your device accesses our servers and what information and files have been downloaded to the App based on your device number.
• Cookies
  • Cookies are pieces of information stored directly on the computer that you are using. Cookies allow us to collect information such as browser type, time spent on the Services, pages visited, language preferences,  and other traffic data.  We and our service providers use the information for security purposes, to facilitate navigation, to display information more effectively, and to personalize your experience.  We also gather statistical information about use of the Services in order to continually improve their design and functionality, understand how they are used, and assist us with resolving questions regarding them.  We do not currently respond to browser do-not-track signals. If you do not want information collected through the use of cookies, most browsers allow you to automatically decline cookies or be given the choice of declining or accepting a particular cookie (or cookies) from a particular website.  You may also wish to refer to http://www.allaboutcookies.org/manage-cookies/index.html. If, however, you do not accept cookies, you may experience some inconvenience in your use of the Services.   
• Pixel tags and other similar technologies.
  • Pixel tags. Pixel tags (also known as web beacons and clear GIFs) may be used to, among other things, track the actions of users of the Services (including email recipients), measure the success of our marketing campaigns, and compile statistics about usage of the Services and response rates.
  • Analytics. We use Google Analytics, which uses cookies and similar technologies to collect and analyze information about use of the Services and report on activities and trends.  This service may also collect information regarding the use of other websites, apps and online resources.  You can learn about Google’s practices by going to google.com/policies/privacy/‌partners/, and exercise the opt-out provided by Google by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
• Invisible reCAPTCHA. We use Google’s invisible reCAPTCHA application on our Services in order to protect against spam and other automated abuse.  The reCAPTCHA tool may make use of cookies, as well as other information like IP address, date, time, language, screen size and resolution, and mouse movements.  The use of the reCAPTCHA tool and any information collected through the tool are subject to Google’s privacy policy, available at https://policies.google.com/privacy, and Google’s terms of service, available at https://policies.google.com/terms?hl=en.

Uses and Disclosures of Other Information

We may use and disclose Other Information for any purpose, except where we are required to do otherwise under applicable law.  If we are required to treat Other Information as Personal Information under applicable law, we may use and disclose it for the purposes for which we use and disclose Personal Information as detailed in this Policy.  In some instances, we may combine Other Information with Personal Information.  If we do, we will treat the combined information as Personal Information as long as it is combined.

SECURITY

We seek to use reasonable organizational, technical and administrative measures to protect Personal Information within our organization.  Unfortunately, no data transmission or storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure, please immediately notify us in accordance with the “Contact Us” section below.

CHOICES AND ACCESS

Your choices regarding our use and disclosure of your Personal Information

We give you choices regarding our use and disclosure of your Personal Information for marketing purposes.  You may opt out from:

1. Receiving marketing-related emails from us. If you no longer want to receive marketing related emails from us on a going-forward basis, you may opt out by following the unsubscribe instructions in each such email.
2. Our sharing of your Personal Information with affiliates for their direct marketing purposes. If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with our affiliates for their direct marketing purposes, you may opt out of this sharing by sending us an email at privacy@accessinvestments.com.
3. Our sharing of your Personal Information with unaffiliated third parties for their direct marketing purposes. If you would prefer that we discontinue sharing your Personal Information on a going-forward basis with unaffiliated third parties for their direct marketing purposes, you may opt out of this sharing by sending us an email at privacy@accessinvestments.com.

We will try to comply with your request(s) as soon as reasonably practicable.  Please note that if you opt out of receiving marketing related emails from us, we may still send you important administrative messages, from which you cannot opt out.

RETENTION PERIOD

We retain Personal Information for as long as needed or permitted in light of the purpose(s) for which it was obtained and consistent with applicable law.

The criteria used to determine our retention periods include:

• The length of time we have an ongoing relationship with you and provide the Services to you;
• Whether there is a legal obligation to which we are subject (for example, certain laws require us to keep records of your transactions for a certain period of time before we can delete them); or
• Whether retention is advisable in light of our legal position (such as in regard to applicable statutes of limitations, litigation or regulatory investigations).

THIRD PARTY SERVICES

This Privacy Policy does not address, and we are not responsible for, the privacy, information, or other practices of any third parties, including any third party operating any website or service to which the Services link.  The inclusion of a link on the Services does not imply endorsement of the linked site or service by us or by our affiliates.

In addition, we are not responsible for the information collection, use, disclosure, or security policies or practices of other organizations, such as LinkedIn, Twitter, Facebook, Instagram, Apple, Google, Microsoft, RIM, or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider, or device manufacturer, including with respect to any Personal Information you disclose to other organizations through or in connection with our Social Media Pages or App.

JURISDICTION AND CROSS-BORDER TRANSFER

Your Personal Information may be stored and processed in any country where we have facilities or in which we engage service providers, and by using the Services you understand that your information will be transferred to countries outside of your country of residence, including the United States, which may have data protection rules that are different from those of your country.

THIRD PARTY PAYMENT SERVICE

The Services may provide functionality allowing you to participate in investment transactions using third-party banking or payment services with which you have created your own account.  When you use such a service to invest, your Personal Information will be collected by such third party and not by us, and will be subject to the third party’s privacy policy, rather than this Privacy Policy.  We have no control over, and are not responsible for, this third party’s collection, use, and disclosure of your Personal Information.

RETAIL INVESTORS

If you are a retail user of our Services, please refer to the “Regulation S-P” section below.

UPDATES TO THIS PRIVACY POLICY

The “Last Updated” legend at the top of this Privacy Policy indicates when this Privacy Policy was last revised.  Any changes will become effective when we post the revised Privacy Policy on the Services.

CONTACT US

If you have any questions about this Privacy Policy, please contact us at info@accessinvestments.com, or: 515 E. Las Olas Blvd., Suite 920, Fort Lauderdale, FL 33301.

Because email communications are not always secure, please do not include credit card or other sensitive information in your emails to us.