VOLEON PRIVACY POLICY
Last Updated: April 9, 2024
This Privacy Policy (“Privacy Policy” or “Policy”) explains how Voleon Capital Management LP, d/b/a The Voleon Group, and certain U.S. affiliates (collectively “Voleon,” or “we,” or “us,” or “our”) collects personal information based on your interactions with us online, including when you view our website or request information from us (collectively, the “Services”). This Policy applies to our collection and use of personal information and describes rights you may have with respect to your personal information. By using this website and otherwise interacting with us, you agree to the terms of our Terms of Use including this Policy.
This Policy does not cover the personal information we collect about employees and independent contractors, or job applicants.
Notice at Collection: Personal Information We Collect
We collect the following categories of personal information (including non-public personal information):
- Personal identifiers: name, email address, your home or billing address, telephone numbers, fax numbers, customer number, account name and password, information related to customer reviews, IP address, Social Security number
- Commercial and financial information: records of products ordered or considered; other purchasing or consuming histories; and payment information; power of attorney.
- Internet or other electronic activity information: your device and browser type, your browsing and search history on our website, and information regarding your interaction with our website and our advertisements
- Professional information: job title, employment history, information about your employer
- Audio, visual information: recordings of customer service calls for quality assurance purposes; recordings of video webinars; security camera footage
- Inferences drawn from personal information we collect
- Sensitive personal information: Social Security number, driver’s license, state identification card, or passport number; account log‐in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; racial or ethnic origin; and the contents of mail or email
Notice at Collection: Purposes for Collection of Personal Information
We collect your personal information to provide the Services; to contact you from time to time; to provide you with information about our business; for customer support; to deliver advertisements and marketing promotions and offers about products we think may be of interest to you; to respond to your inquiries; and to customize your experience.
We also use personal information to monitor or improve our website; for internal business analysis; to prevent fraud, activities that violate our Terms of Service or other contracts, or that are illegal; and to protect our rights and the rights and safety of our users or others.
For those who interact with us in a commercial capacity, we use your personal information to engage in business transactions with the entity you represent and to market to or engage in diligence with the entities you represent.
Notice at Collection: Categories of Personal Information We Sell or Share or Use for Targeted Advertising
We do not sell personal information or share it for purposes of cross-context behavioral advertising.
Notice at Collection: Retention Periods
We retain the categories of personal information we collect for the length of time necessary to provide our Services and to comply with legal obligations or to protect our legal rights.
Sources From Which We Collect Personal Information
We collect personal information directly from our customers, website users, and representatives of entities with which we do business or may do business.
Use or Disclosure of Sensitive Personal Information
We may collect sensitive personal information as part of the investor diligence process for which we utilize a third-party service provider to perform required know-your-customer activities. We do not use or disclose sensitive personal information to create profiles about or infer characteristics about individuals, or for any purposes other than providing our Services.
Disclosure of Personal Information For Business Purposes in the Past 12 Months
The following chart describes the categories of personal information we disclosed to third parties, including non-affiliated entities, for a business purpose in the 12 months prior to the date of this Policy:
| Categories of Personal Information | Categories of Third Parties to Which We Disclosed Personal Information for Business Purposes |
|---|---|
| Personal identifiers: name, email address, your home or billing address, telephone numbers, customer number, information related to customer reviews, IP address | Service providers that process payments, verify customer information, manage customer information and provide customer service (including through any call center or website chat features), facilitate email communications, provide security services and cloud-based data storage, host our website and assist with other IT-related functions, provide analytics information, and provide legal and accounting services. |
| Commercial and financial information: records of products ordered or considered; other purchasing or consuming histories; and payment information | Service providers that process payments, verify customer information, manage customer information and provide customer service, facilitate email communications, provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products, provide analytics information, and provide accounting services |
| Internet or other electronic activity information: your device and browser type, your browsing and search history on our website, and information regarding your interaction with our website and our advertisements. | Service providers that provide security services and cloud-based data storage, host our website and assist with other IT-related functions, advertise and market our products on our behalf, and provide analytics information. |
| Professional information: job title, information about your employer | If you are, are employed by, or represent a customer or commercial partner—service providers that manage customer or commercial partner contact information. |
| Sensitive personal information: Social Security number, driver’s license, state identification card, or passport number; account log‐in, financial account, debit card, or credit card number in combination with any required security or access code, password, or credentials allowing access to an account; racial or ethnic origin; and the contents of mail or email | Service providers that perform prospective investor diligence and know-your-customer activities. |
We do not offer an option to limit our sharing with these third-parties, including non-affiliated entities, because the information is shared for our every day business purposes.
Business Purposes for Such Disclosures
We disclosed the aforementioned categories of personal information to the categories of third parties identified above for the following purposes: to manage customer and vendor accounts and relationships; to process payments; to verify customers’ identities; to fulfill orders and transactions; to engage in advertising and marketing on our behalf to offer our products and services to you, as well as joint marketing with other financial companies; to operate and secure our IT systems; to prevent fraud and other illegal activities; and to obtain professional advice about legal and accounting matters.
Additional Information About How We May Disclose Personal Information and Purposes for Disclosures
To Affiliates. We may share your personal information, including information about your transactions and experiences, with our affiliates for every day business purposes, such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus. Because we only share your personal information to affiliates for every day business purposes, you do not have the option to opt out of such sharing.
Other Circumstances. We may also disclose your personal information as required or permitted by law to comply with a subpoena or similar legal process or government request, or when we believe in good faith that disclosure is legally required or otherwise necessary to protect our rights and property or the rights, property or safety of others, including to law enforcement agencies, and judicial and regulatory authorities. We may also disclose your personal information to third parties to help detect and protect against fraud or data security vulnerabilities. And we may disclose or transfer your personal information to a third party in the event of an actual or potential sale, merger, reorganization of our entity or other restructuring. You do not have a right to limit sharing for these purposes.
We do not share your personal information with third parties for those third parties’ own marketing purposes.
Our Use of Cookies and Analytics
We may use cookies, pixel tags, web beacons and other similar tracking technologies (“tracking technologies”) to automatically collect information through our Services. Tracking technologies may be, for example, snippets of code that run on our website or small data files placed on your computer, tablet, mobile phone, or other devices that record certain pieces of information when you visit our Services. We may use these tracking technologies to help identify irregular behavior, to prevent fraudulent activity and to improve security, as well as to make it possible for you to save your preferences and help us understand how you interact with our Services.
We also utilize third-party tracking technologies on our Services for analytics purposes. These technologies help us understand how users interact with our Services, and the third-parties that provide them agree not to sell or disclose any of the usage information they capture (except to subcontractors who assist in providing the service). These third parties are our service providers and they may use certain technologies to record your interactions with the Services, including without limitation, your keystrokes and mouse clicks, and information about when, how and from where you accessed our Services. This information is used to help us manage our Services and to optimize the user experience.
You may set your browser to notify you when you receive a certain type of tracking technology, a cookie. Many web browsers also allow you to block cookies. You can disable cookies from your computer system by following the instructions on your browser or at www.youradchoices.com.
Personal Information of Minors
Our products and website are not directed to minors under the age of 18 and we do not knowingly sell or share for purposes of behavioral advertising the personal information of minors, including minors under 16 years of age.
Do Not Track Signals
Do Not Track (“DNT”) is a privacy preference that users can set in certain web browsers. Please note that we do not respond to or honor DNT signals.
Third Party Websites
Our Services may contain links to third-party websites. This Policy does not govern how those third parties collect or use personal information and we do not endorse or have control over their practices. The privacy policies and terms of use for those third parties’ websites/apps govern those companies’ privacy practices. We are not responsible for the content or privacy practices of any third-party websites or platforms.
How We Keep Your Personal Information Secure
We implement and maintain reasonable security appropriate to the nature of the personal information that we collect, use, retain, transfer or otherwise process. However, there is no perfect security, and reasonable security is a process that involves risk management rather than risk elimination. While we are committed to maintaining a reasonable information security program, no such program can be perfect; in other words, all risk cannot reasonably be eliminated. Data security incidents and breaches can occur due to factors that cannot reasonably be prevented. Accordingly, it cannot be assumed that the occurrence of any given incident or breach results from our failure to implement and maintain reasonable security.
Changes to This Policy
We will review and update this Policy from time to time. If changes are made, we will update the Privacy Policy and reflect the date of such modification in the date above. If the changes are material, you will be notified via email or a notice on our website.
Accessibility
We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at contact@voleon.com.
Contact Us
If there are any questions regarding this Privacy Policy or to request a copy of this Privacy Policy in another format you may contact us at privacy@voleon.com.
CALIFORNIA PRIVACY RIGHTS
If you are a California resident, the California Consumer Privacy Act (“CCPA”) and other laws provide you with the following rights with respect to personal information we collect and process about you:
Your Right To Know About Personal Information We Collect
You can ask us for the following information from us with respect to the personal information we have collected about you since January 1, 2022:
- Specific pieces of personal information we have collected about you;
- Categories of personal information we have collected about you;
- Categories of sources from which such personal information was collected;
- Categories of personal information that the business disclosed for a business purpose about the consumer;
- Categories of third parties to whom the personal information was disclosed for a business purpose; and
- The business or commercial purpose for collecting your personal information.
Your Right To Request Deletion of Personal Information We Have Collected From You
Upon your request and subject to exceptions in the law, we will delete the personal information we have collected about you.
Your Right to Request to Correct Personal Information We Hold About You
You have the right to request that we correct personal information we hold that you believe is not accurate. We will take steps to determine the accuracy of the personal information that is the subject of your request to correct, and in doing so will consider the totality of the circumstances relating to the personal information you have identified as being incorrect. We may ask that you provide documentation regarding your request to correct to assist us in evaluating the request.
California Shine the Light
California Civil Code Section 1798.83, also known as the “Shine the Light” law, permits California residents to annually request, free of charge, information about the personal information (if any) disclosed to third parties for a third party’s own direct marketing purposes in the preceding calendar year. We do not disclose personal information to third parties for such a purpose.
Our Commitment to Honoring Your Rights
If you exercise any of the rights explained in this Privacy Policy, we will continue to treat you fairly. If you exercise your rights under this Privacy Policy, you will not be denied or charged different prices or rates for goods or services, or provided a different level or quality of goods or services than others.
Exercising Your Rights and How We Will Respond
To exercise your rights to know, delete or correct your personal information, or to ask a question, submit your request through voleon.com/contact.php, contact us at privacy@voleon.com, or call 1-877-314-0860. For such requests, we will first acknowledge receipt of your request within 10 business days of receipt of your request. We will then provide a substantive response to your request as soon as we can, generally within 45 days from when we receive your request, although we may be allowed to take longer to process your request in certain jurisdictions or under certain circumstances. If we expect your request is going to take us longer than normal to fulfill, we will let you know.
We usually act on requests and provide information free of charge, but we may charge a reasonable fee to cover our administrative costs of providing the information in certain situations. In some cases, the law may allow us to refuse to act on certain requests. When this is the case, we will endeavor to explain why.
Verification of Identity - Requests to Know, Delete or Correct
We will ask you for two pieces of personal information and attempt to match those to information that we maintain about you.
If we are unable to verify your identity with the degree of certainty required, we will not be able to respond to the request. We will notify you to explain the basis of the denial.
Authorized Agents
You may designate an agent to submit requests on your behalf. The agent can be a natural person or a business entity.
If you would like to designate an agent to act on your behalf, you and the agent will need to comply with our verification process. If the agent submits a request, the agent will need to provide us with your signed permission indicating the agent has been authorized to submit the request on your behalf. We will also require that you verify your identity directly with us or confirm with us that you provided the agent with permission to submit the request.
Please note that this subsection does not apply when an agent is authorized to act on your behalf pursuant to a valid power of attorney. Any such requests will be processed in accordance with California law pertaining to powers of attorney.
Authorized agents can submit a request to privacy@voleon.com.