LAST UPDATED: April 15, 2021
“Personal Information” is information that identifies you as an individual or relates to an identifiable individual. The Website collects Personal Information, including:
- Email Address
- Postal address
- Telephone number
- IP address (we may also derive your approximate location from your IP address)
- User ID, PIN and password
- Social Security Number and Tax ID
- Investment transaction information
If you are a resident of California, please see “Additional Information Regarding California Residents” below for more information about how we handle your Personal Information and how to exercise your rights under the California Consumer Privacy Act.
Use of Personal Information
We and our service providers may use Personal Information for the following purposes:
- Providing the functionality of the Website and fulfilling your requests
- To arrange access to your registered account and provide you with related services.
- To respond to your inquiries, such as when you contact us via one of our online contact forms.
- To complete your requested unitholder investment transactions.
- To send administrative information to you, such as changes to our terms and policies.
- To allow you to send and receive messages through the Website if you choose to do so.
- Providing you with our newsletter and/or other marketing materials
- To send you marketing related emails, with information about our services, new products and other news 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 Website.
- 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 Website 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 data analysis, for example, to improve the efficiency of our Website.
- For 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.
- To develop new products and services.
- To enhance, improve, repair, maintain, or modify our current products and services, as well as to take quality and safety assurance measures.
- To identify usage trends, for example, to understand which parts of our Website are of most interest to users.
- To determine the effectiveness of our promotional campaigns, so that we can adapt our campaigns to the needs and interests of our users.
Disclosure of Personal Information
We may 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, transaction processing, fraud prevention, information technology and related infrastructure provision, customer service or support, marketing and ad agencies, email delivery, auditing, and other services.
- To third parties with which we do business that have a pre-existing relationship with you, such as broker/dealers, financial advisors and custodians.
- To other third-party business partners, such as financial institutions and other entities that are involved in the investment process.
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” is any information that does not reveal your specific identity or does not directly relate to an identifiable individual. The Website collects Other Information such as:
- Browser and device information
- Information collected through cookies and other technologies
- Demographic 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
Collection of Other Information
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, and Internet browser type and version. We use this information to ensure that the Website functions properly.
Uses and Disclosures of Other Information
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
If you no longer want to receive marketing-related emails from us on a going-forward basis, you may opt-out by responding to such emails or contacting [email protected] We will try to comply with your request 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.
If you are a resident of California, under 18, and a registered user of the Website, you may ask us to remove content or information that you have posted to the Website by writing to [email protected] Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
THIRD PARTY SERVICES
USE OF WEBSITE BY MINORS
The Website is not directed to individuals under the age of eighteen (18), and we do not knowingly collect Personal Information from individuals under 18.
The Website is controlled and operated by us from the United States and is not intended to subject us to the laws or jurisdiction of any state, country or territory other than that of the United States.
ADDITIONAL INFORMATION REGARDING NEVADA RESIDENTS
We do not sell Covered Information as defined under Nevada law. If you would like to make a further inquiry regarding the selling of your Covered Information, as defined under Nevada law, please contact [email protected].
ADDITIONAL INFORMATION REGARDING CALIFORNIA RESIDENTS
Pursuant to the California Consumer Privacy Act of 2018 (“CCPA”), we are providing the following additional details regarding the categories of Personal Information that we collect, use and disclose about California residents. This CCPA section does not apply to our job applicants, employees, contractors, owners, directors, or officers where the Personal Information we collect about those individuals relates to their current, former, or potential role at TGIF. Under the CCPA, “Personal Information” is information that identifies, relates to, or could reasonably be linked with a particular California resident or household.
Sources of Personal Information
We collect this Personal Information from you, such as when you register for an account or undertake a transaction with us, and from other categories of sources: entities with which we do business that have a pre-existing relationship with you, joint marketing partners and social media platforms.
Categories of Personal Information Collected and Disclosed
The following chart details which categories of Personal Information about California residents we may collect, as well as which categories of Personal Information we have collected and disclosed for our operational business purposes in the preceding 12 months.
|Categories of Personal Information||Disclosed to Which Categories of Third Parties for Operational Business Purposes|
|Identifiers, such as name, contact information, IP address, online identifiers, Social Security numbers and other government-issued ID numbers||Our affiliated entities; trusted third-party service providers; entities with which we do business that have a pre-existing relationship with you, such as broker/dealers, financial advisors and custodians; and third-party business partners, such as financial institutions and other entities that are involved in the investment process|
|Personal information, as defined in the California customer records law, such as name, contact information, signature and financial information||Our affiliated entities; trusted third-party service providers; entities with which we do business that have a pre-existing relationship with you, such as broker/dealers, financial advisors and custodians; and third-party business partners, such as financial institutions and other entities that are involved in the investment process|
|Characteristics of protected classifications under California or federal law, such as sex, national origin, citizenship, immigration status and marital status||Our affiliated entities; trusted third-party service providers; entities with which we do business that have a pre-existing relationship with you, such as broker/dealers, financial advisors and custodians; and third-party business partners, such as financial institutions and other entities that are involved in the investment process|
|Commercial information, such as transaction information and payment history||Our affiliated entities; trusted third-party service providers; entities with which we do business that have a pre-existing relationship with you, such as broker/dealers, financial advisors and custodians; and third-party business partners, such as financial institutions and other entities that are involved in the investment process|
|Internet or network activity information, such as browsing history, online behavior, interest data, and interactions with our and other websites and systems||Our affiliated entities and trusted third-party service providers|
|Professional or employment-related information, such as you employer or the entity with which you are affiliated||Our affiliated entities; trusted third-party service providers; entities with which we do business that have a pre-existing relationship with you, such as broker/dealers, financial advisors and custodians; and third-party business partners, such as financial institutions and other entities that are involved in the investment process|
We may use this Personal Information to operate, manage, and maintain our business, to provide our products and services, and to accomplish our business purposes and objectives, including, for example, to: develop, improve, repair, and maintain our products and services; personalize, advertise, and market our products and services; conduct research, analytics, and data analysis; maintain our facilities and infrastructure; undertake quality and safety assurance measures; conduct risk and security control and monitoring; detect and prevent fraud; perform identity verification; perform accounting, audit, and other internal functions, such as internal investigations; comply with law, legal process, and internal policies; maintain records; carry out corporate transactions, such as mergers, joint ventures or acquisitions; and exercise and defend legal claims.
Under the CCPA, if a business sells Personal Information, it must allow California residents to opt out of the sale of their Personal Information. However, we do not sell and have not sold Personal Information, as “sale” is defined in the CCPA. For example, and without limiting the foregoing, we do not sell the Personal Information of minors under 16 years of age.
If you are a California resident, you may request that we:
- Disclose to you the following information covering the 12 months preceding your request:
- The categories of Personal Information we collected about you and the categories of sources from which we collected such Personal Information;
- The specific pieces of Personal Information we collected about you;
- The business or commercial purpose for collecting Personal Information about you; and
- The categories of Personal Information about you that we otherwise shared or disclosed, and the categories of third parties with whom we shared or to whom we disclosed such Personal Information (if applicable).
- Delete Personal Information we collected from you.
To make a request for the disclosures or deletion described above, please contact us at 800-358-8951 or [email protected]. We will verify and respond to your request consistent with applicable law, taking into account the type and sensitivity of the Personal Information subject to the request. We may need to request additional Personal Information from you, such as mailing address, account number, or last 4 digits of SSN in order to verify your identity and protect against fraudulent requests. If you maintain a password-protected account with us, we may verify your identity through our existing authentication practices for your account and require you to re-authenticate yourself before disclosing or deleting your Personal Information. If you make a deletion request, we may ask you to verify your request before we delete your Personal Information.
You have the right to be free from unlawful discrimination for exercising your rights under the CCPA.
If you want to make a request as an authorized agent on behalf of a California resident, you may use the submission methods noted above. As part of our verification process, we may request that you provide, as applicable, proof concerning your status as an authorized agent, which also may include:
- Proof of your registration with the California Secretary of State to conduct business in California; and/or
- A power of attorney from the California resident pursuant to Probate Code sections 4121-4130.
If you are making a request on behalf of a California resident and have not provided us with a power of attorney from the resident pursuant to Probate Code sections 4121-4130, we may also require the resident to:
- Verify the resident’s own identity directly with us; or
- Directly confirm with us that the resident provided you permission to submit the request.