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Privacy Policy

Effective March 3, 2021

Capital Allocators, LLC, a Delaware limited liability company (also referred to as “we,” “our”, or “us”) provides this Privacy Policy (this “Policy”) to inform you about our collection, use, disclosure, and storage of data about you that we collect via this website and the content, functionality, and services on our website, which we refer to collectively as the “Website.” You agree to this Policy, and other policies on our Website by using the Website or by accepting this Policy in connection with creating an account with us.

Changes to this Policy. We may change this Policy from time to time, and such changes will be effective upon our posting a new version on the Website. We will also update the date at the top of this Policy to reflect the effective date of any such changes, and we encourage you to periodically review this Policy for any updates. Your continued use of the Website and/or creation of an account after we have posted an updated version of this Policy will automatically constitute your acceptance of such version.

Information We Collect and Receive. We may collect and process some or all of the following types of information about you:

  • Personal Information​. “Personal Information” means information that could be directly associated with you, or used to contact or identify you, without the aid of additional information, including, without limitation, your name, age, date of birth, gender, address, email address, profession, industry, social media login details, telephone number, photograph, and username/password, certain content (and any personally-identifiable metadata contained therein) you upload to, or post on, the Website, and the recipient and content of messages you send through the Website.
  • Usage Information​. “Usage Information” means information that is not Personal Information, but that relates to your usage of the Website or that is necessary for the proper functioning or improvement of the Website, including: (i) times and dates and the extent of your usage of the Website; (ii) time zone, language, screen resolution, and other usage preferences you select when using the Platform; (iii) device keyboard settings; (iv) the content you view, like, comment on, share, follow, message, and otherwise interact with, as well as the foregoing that other users do with respect to your account and/or user content; (v) usage history such as areas and pages within the Website that you access or use and/or which buttons in the Website you click on; (vi) search terms you type in on the Website; (vii) the URL or advertisement that may have referred you to the Website; (viii) the search terms you entered into a search engine or app store that may have led you to the Website; (viii) the mobile platform or service provider you use, and (ix) other device and Website access information such as your browser type, operating system, IP address, referring/exit pages, and other unique device identifiers, as well as your push notification token.

While Usage Information is non-identifying on a standalone basis, we may in certain instances combine this information with other information collected on the Website. If we ever combine non-identifying information with Personal Information or other information that enables you to be identified, we will treat such combined information as Personal Information. We do not currently use your Personal Information for automated decision making which produces legal effects concerning you or similarly significantly affects you.

How We Collect and Receive Information. We collect Personal Information and Usage Information in the following ways:

  • Information Provided Directly By You. When you create an account, upload or post content, transmit messages using the Website, subscribe for a newsletter, fill out Website forms or otherwise contact us, you may choose to provide us Personal Information. The Website and its servers also automatically collect certain Usage Information as you interact with the Website.
  • Information Provided via Facebook, Instagram or Twitter Connect or other Third Parties. You may have the option to use your Facebook, Instagram, or Twitter account, or your account with any other social media platform with which we partner for cross-platform account synchronization from time-to-time to set up a Premium Member account, rather than signing up for a Premium Member account directly via the Website. As part of such connection, certain Personal Information or Usage Information may be transmitted to us. For more information on this data transmission, please see the Facebook, Instagram, or Twitter privacy policy, as applicable. We may also receive Personal Information or Usage Information from other third parties; for example, we may supplement certain information that we collect from you with outside records, or third parties may provide us with information about you in connection with a co-marketing agreement.

How We Use Information. We use Personal Information in the following ways:

  • for the purposes for which you provided it to us (e.g., to manage your subscription, create or update your account, register you for promotions, newsletters, or events, or process transactions, as applicable);
  • to respond to your inquiries and communications;
  • to improve, maintain, and operate the Website;
  • to inform you about opportunities, events, or services in which you may be interested, including those offered by our affiliates;
  • to investigate and prevent possible fraud;
  • to exercise or defend our rights and comply with statutory and regulatory requirements, including responding to lawful requests for information by governmental authorities; and
  • for other reasons with your prior consent.

You can opt out of receiving promotional or marketing emails from us at any time by clicking the unsubscribe, opt-out, or similar link at the bottom of any such emails. Please note we may still contact you for non-marketing reasons (e.g., in connection with your membership, events you have registered for or attended, or any other transactions involving you).

We may use Usage Information (which does not identify you personally) for any manner we deem appropriate, including without limitation to improve, maintain, and operate the Website.

How We Share Information. We will not sell your Personal Information to third parties. We may share your Personal Information with our affiliates and as needed to fulfill the purposes described in the “How We Use Information” section above, including:

  • with other users to fulfil your messages and posts on the Website;
  • with third parties involved in sponsoring, offering, or administering a sweepstakes, contests, or promotions in connection with the Website, or to the public in connection with winner selection, prize fulfillment, and as required by law or permitted by the Promotion’s official rules, such as on a winner’s list;
  • with our service providers, such as email service providers, customer support providers, and payment processors, who are only permitted to use the data on our behalf;
  • as necessary to exercise or defend our rights or comply with applicable law or orders from law enforcement and other governmental authorities; and
  • to other third parties with your prior consent.

Additionally, in the event of a merger, consolidation, sale, or transfer of all or substantially all of our assets or business, one of the assets that would generally be transferred is the data we have collected, which would be transferred subject to the applicable version of this Policy.

We may disclose Usage Information (which does not identify you personally) to any parties and for any purposes we deem appropriate.

Your California Privacy Rights. This section provides additional details about the Personal Information we may collect about California-resident Users and the rights afforded to them under California Civil Code Section 1798.83 and the California Consumer Privacy Act of 2018 (“CCPA​”). California-resident users are entitled to additional privacy rights which are further described below. California-resident users who wish to request further information about our compliance with the above referenced statutes or who have questions more generally about our Privacy Policy or the CCPA and our privacy commitments to our users should not hesitate to contact us in accordance with the procedures set forth below.

California Residents’ Rights and Choices with Respect to Personal Information. Subject to certain limitations, the CCPA provides California residents with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights, which specifically includes:

  • Right to request to know more details about the categories or specific pieces of Personal Information we collect (including how we use and disclose this information);
  • Right to delete their Personal Information;
  • Right to opt out of any “sales” that may be occurring; and
  • Right to not be discriminated against for exercising the foregoing rights.

Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights​ subsection below), we will disclose to you:

  • The categories of Personal Information we collected about you.
  • The categories of sources for the Personal Information we collected about you.
  • Our business or commercial purpose for collecting or selling that Personal Information.
  • The categories of third parties with whom we share that Personal Information.
  • The specific pieces of Personal Information we collected about you (also called a data portability request).
  • If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing the following: (i) sales, identifying the Personal Information categories that each category of recipient purchased; and (ii) disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Deletion Request Rights. You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your Personal Information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

  • Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
  • Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
  • Debug products to identify and repair errors that impair existing intended functionality.
  • Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
  • Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
  • Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
  • Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
  • Comply with a legal obligation.
  • Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by email at ​

Only you, or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

  • Provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative.
  • Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

Making a verifiable consumer request does not require you to create an Account with us. However, we do consider requests made through your password protected Account sufficiently verified when the request relates to Personal Information associated with that specific account. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format. We endeavor to respond to a verifiable California residents request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing. If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

Personal Information Sales Opt-Out and Opt-In Rights. We will not sell your Personal Information to any party. If in the future, we anticipate selling your Personal Information to any party, we will provide you with the opt-out and opt-in rights required by the CCPA.

Non-Discrimination. We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

  • Deny you products or services on the Website.
  • Charge you different prices or rates for products or services on the Website, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of products or services on the Website
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of products or services on the Website.

European Union Users. European Union data protection law requires a “lawful basis” for collecting and retaining Personal Information from citizens or residents of the European Economic Areas (“​EEA​”). Our lawful basis for collecting such information about you is permitted under ​Article 6, Sections 1(a), 1(b), 1(c) and 1(f) of the EU general data protection regulation 2016/679 (“​GDPR​”), which are summarized below.

  • Consent​: In certain cases, you have affirmatively provided us with your consent to collect your Personal Information for a specific purpose, such as providing your email address when you create your Account or making certain User Content publicly available on the Website.
  • Contract​: We may need your Personal Information to comply with our contractual obligation to deliver the Website, such as fulfilling any future subscription based, or other transactional, services.
  • Legal Obligations​: Sometimes the law requires us to collect and use your Personal Information, such as applicable tax laws that may require us to retain records of payments made through the Website.
  • Legitimate Interests​: We have fair reason to use your Personal Information and we do so in ways which do not harm your interests and rights, such as to pursue our legitimate interests in a way that might reasonably be expected as part of running our business and that does not materially impact your rights, freedom, or interests. Such ways are described in the “How We Use Information” and “How We Share Information” sections of this Policy.

To the extent established under applicable law, European Union or Swiss residents may have the right:

  • to access, review, and update their Personal Information;
  • to restrict our processing of their Personal Information;
  • to request that we provide them a copy of, or access to, their Personal Information in structured, commonly used and machine-readable format (or that we transfer their Personal Information to another controller, when technically feasible);
  • to withdraw their consent when our processing of their Personal Information is based on consent (and not another legitimate basis);
  • to request that we delete their Personal Information (subject to certain limitations); and
  • to lodge a complaint with the applicable supervisory authority in the EU. Before you do this, we ask that you please contact us directly in order to give us an opportunity to work directly with you to resolve any concerns about your privacy.

To make any of the above requests, please contact us as set forth at the end of this Policy. We may require verification of your identity before further processing your request. In certain instances, we may be permitted by law to decline some or all of such request. Please note that if you make unfounded, repetitive, or excessive requests (as determined in our reasonable discretion) to access your Personal Information, you may be charged a fee to the extent permitted by law.

Cookies. If you have permitted your computer to accept “cookies,” we may use “cookies” to keep, and sometimes track, information about you. Cookies are small data files that are sent to your browser or related software and apps, from a Web server and stored on your mobile device, or computer’s hard drive. Cookies track where you travel on our Website and what you look at, transact and favorite. They may store the information in your account, and/or your Username and/or password, and we may use them to deliver specific messages to you (for example, to announce a new property that was added since the last time you visited the Website). A cookie may enable us to link your use of our Website to other information about you, including your Personal Information. All of these purposes serve to improve and personalize your experience on our Website. Most Web browsers can be set to inform you when a cookie has been sent to you and provide you with the opportunity to refuse that cookie. However, refusing a cookie may, in some cases, preclude you from using, or negatively impact the display or function of, the Website or certain areas or features of the Website.

Do Not Track Requests. Please note that your browser setting may allow you to automatically transmit a “Do Not Track” signal to websites and online service you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, we do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” please visit ​​.

Location and Security. We are based in the United States. By using the Website, you consent to your Personal Information being transferred to and stored in the United States. The security of your information is important to us, and we take steps to ensure that your information is treated securely and in accordance with applicable laws. Unfortunately, the transmission of information via the internet is not completely secure, and any transmission is at your own risk. We follow generally accepted industry standards to protect your information, both during transmission and once we receive it, and to keep such Information confidential (unless it is non-confidential by nature, for example, publicly available information or information you post on public portions of the Website). In the unlikely event that an unauthorized third party compromises our security measures, we will not be responsible for any damages directly or indirectly caused by an unauthorized third party’s ability to view, use or disseminate such information. If you ever discover inaccuracies in our data or if your Personal Information changes, we urge you to notify us immediately. Children. The Website is not directed toward children under 13. If a parent or guardian becomes aware that his or her child has provided us with Personal Information, the parent or guardian should contact us as set forth at the end of this Policy, and we will take reasonable steps to promptly remove such data from our systems (subject to any applicable, legally required or permitted, retention standards).

Third Party Sites. The Website may include links to third party sites and services. If you visit or use such third party sites and services, please be mindful that the relevant third party controls the cookies and other technologies it uses on its sites and how it collects, uses, and shares your information. This Policy only governs our own privacy practices; please review the applicable third party privacy policy when visiting or using any third party sites or services.

Contacting Us. If you have any questions or comments about this Policy, the ways in which we collects and uses your information described above and generally, your choices and rights regarding such use, or wish to exercise your rights under applicable privacy law, please do not hesitate to contact us by email at ​

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