The Personal Information we collect and otherwise process falls into two categories:

(i) information you voluntarily provide us (or other external sources provide us) when you visit the Site and submit your information or otherwise interact with us both online and offline; and

(ii) tracking information gathered as you visit the Site.

PERSONAL INFORMATION YOU PROVIDE
The types of Personal Information we collect and otherwise process about you depends on the product or service you have with us and the nature of our relationship with you. We may collect your Personal Information in various ways, including via email, telephone, videoconference, a Site contact form, as part of a transaction, and through other documents, forms, questionnaires and correspondence (such as your subscription agreement and related documents). Wherever reasonably practicable, we will endeavor to collect information about you from you personally.

We may collect the following categories of Personal Information about you:

• Identifiers (e.g., real name, alias, postal address, email address, social security number, driver’s license number, passport number, other government ID, signature, telephone number, and spouse’s name) and other contact information;
• Financial information (e.g., tax-related identification numbers, information and codes, wire transfer information, banking details and other account details);
• Protected characteristic information (e.g., age, date of birth, nationality, citizenship, country of residence, gender, race, and other types of such information);
• Commercial information (e.g., assets, income, account numbers, transaction, investment and withdrawal history, net worth, accounts at other institutions, information concerning source of funds and any applicable restrictions on your investment, such as political exposure or sanctions);
• Details of your company’s directors, shareholders, secretaries, authorized signatories and other comparable officers and/or beneficiaries, and identification documents;
• Professional or employment-related information (e.g., current or past job history, education, personal references); and/or
• Inferences drawn (e.g., preferences, characteristics, predispositions, behavior, aptitude, and trends) based on other Personal Information, such as assets, investment experience, risk tolerance, investment activity, and transaction history

Of the above categories of Personal Information that we may collect about you, the following may be considered “sensitive” categories under certain applicable laws: social security number, driver’s license number, financial account information, and racial or ethnic origin. This Privacy Policy, and the practices described herein, applies equally to our collection, use, disclosure and other processing of such “sensitive” Personal Information.

It may be necessary or more practicable at times to collect certain of the Personal Information listed above from external sources, such as:

• A financial adviser, lawyer, broker or other professional advisor;
• Authorized representatives, such as executors or administrators;
• Credit check providers;
• Publicly available registries and other publicly available sources; and/or
• Identification verification and other service providers.

In certain circumstances, we may combine Personal Information that you provide to us with Personal Information that we collect from or about you from such external sources. This may include Personal Information collected in an online or offline context.
PASSIVE INFORMATION COLLECTION & USE OF COOKIES

We may use analytics tools, including third-party services such as Google Analytics, to help us measure traffic, usage, and other trends based on your use of the Site. These tools use various technologies, including cookies or similar technologies, to collect certain information sent by your devices to the Site, including:

• Your browser name;
• The pages you visit on the Site;
• Whether you have previously accessed the Site;
• The IP (Internet Protocol) address for your computer and other online identifiers;
• The type of computer you are using and other technical information about your means of connection to the Site, such as the operating system, relevant plug-ins, and the Internet service providers utilized;
• Navigational data, also known as log files, server logs or clickstream data; and/or
• Other Internet or electronic network activity or information, such as browsing history and activities, search history, and other information regarding your interaction with the Site.

We conduct the passive collection of the above information in a variety of ways, including:

• Through 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 Macintosh), screen resolution, operating system name and version, device manufacturer and model, language and Internet browser type and version;
• Through your use of the Site. When you visit the Site, we may track and collect the usage data, including but not limited to the date and time your device accessed the Site;
• Using 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 Site, pages visited, language preferences, and other traffic data of the Site;
• Using tracking technologies (i.e., to track you across third-party websites);
• Using pixel tags (also known as web beacons and clear GIFs) and other similar technologies;
• Using your IP address. Your IP address is a number that is automatically assigned to the computer that you are using by your Internet service provider. An IP address may be identified and logged automatically in our server log files whenever you access the Site, along with the time of the visit and the page(s) that were visited. Collecting IP addresses is standard practice and is done automatically by many websites, applications and other services.
• If you connect to us from a social network, such as LinkedIn or Facebook, we will collect Personal Information from that social network in accordance with your privacy settings on that social network. The connected social network may provide us with information such as your name, profile picture, network, gender, username, user ID, age or age range, language, country, friends list, follower list, job title, and any other information you have agreed it can share or that the social network provides to us.

If you do not want information collected through the use of cookies, you may choose to set your web browser to refuse cookies, or to alert you when cookies are being sent. However, if you do not accept these cookies, you may experience some inconveniences in your use of the Site and some parts of the Site may not function properly. We do not currently respond to “do not track” signals or other mechanisms that might enable users to opt out of tracking on the Site. To opt out of Google Analytics on the Site, please visit: https://tools.google.com/dlpage/gaoptout.

We may block certain IP addresses if they attempt to access the administrative portions of the Site without authorization.