Website Privacy Policy

Scope

This Website Privacy Policy does not apply to information that we or our service providers collect, use and disclose with respect to individuals who engage with us for investment services. They will receive our separate Privacy Notice governed by federal law at the time they seek such services. This Website Privacy Policy only applies to the information we collect from you through this Site.

Information Collected

We or our technology service provider may collect certain information you provide voluntarily by webform through the Site, including:

• Your name, contact information, company name and email address.
• Any other text information you voluntarily provide to us through our “contact us” feature.

We may use cookies and similar technologies (such as web beacons and pixels) to automatically collect technical information, such as your IP address, browser used to view the Site, operating system, resolution of screen, location, language settings in browser, the site directing to the Site, keywords searched, the number of page views, inferences drawn from any personal information.

Cookies are small text files that are stored on your device when you visit a website. They help us recognize your device and remember certain information about your preferences. The cookies we use may be categorized as follows:

• Essential Cookies: These cookies are necessary for the functioning of the Site and enable you to navigate and use its features. For example, we use reCAPTCHA technology to protect our webforms from spam and abuse.
• Analytical/Performance Cookies: These cookies collect information about how you use our Site and help us improve its performance and functionality.

Analytics cookies (including Google Analytics) load only in accordance with your choices. When you first visit, a consent banner lets you manage non-essential cookies: visitors in the EU and UK are asked to opt in before non-essential cookies are set, while visitors elsewhere may opt out. You can change your choice at any time by clearing cookies in your browser or contacting us at the email address below.

Use of Your Personal Information

We use your personal information for the following business purposes and as otherwise described in this Website Privacy Policy:

• To provide services. We may use your personal information to fulfill or meet the reason you provided such information. This includes our use of your personal information to provide, operate and improve the services provided to you, as well as understand your interests and personalize your experience when visiting the Site. We may use your information to verify your identity or to communicate with you in relation to the services, including by sending announcements, updates, security alerts, and support and administrative messages.
• For marketing and promotional communications. If, as permitted by law, we send marketing or promotional information, we may use your personal information for such marketing, research and other business purposes. You can opt out of our marketing and promotional communications, as your consent is required to receive such communications.
• To improve our services and customer experiences. We may use your personal information to present the Site content in the most effective manner for you and for your computer, to administer the Site and conduct internal operations including for troubleshooting, testing, and research, and to enable your participation in the Site’s interactive, social media or other similar features.
• To promote safety, compliance and fraud prevention. We may use your personal information as we believe necessary or appropriate to: (a) protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims); and (b) protect, investigate, and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.
• With your consent. On other occasions, we may specifically ask for your consent to use your personal information for the purpose(s) that we explain at that time.

If you have provided us with non-personally identifiable information, including anonymous information and aggregate data, we may use such non-personally identifiable information to understand better how visitors use the Site, research demographics, interests and behavior, improve the Site, provide visitors with information and for other similar purposes.

Information We Disclose

It is our policy to not disclose or share your personal information, except in the following circumstances or, with respect to certain non-public information protected by federal law, as otherwise described in our separate Privacy Notice provided to those who engage with us for investment services:

• With affiliates. We may disclose your personal information to our affiliates for our and our affiliates’ everyday business purposes or purposes consistent with our policies.
• With service providers and other third parties. We may disclose or provide access to your personal information with third-party companies and individuals that provide services on our behalf or help us operate the services (such as customer support, hosting, analytics, email delivery, marketing, database management services or marketing services). These third parties may use your personal information only as authorized by their contracts with us.
• With professional advisors. We may also disclose your personal information to professional advisors, such as lawyers, bankers, auditors, and insurers, where necessary in the course of the professional services that they render to us.
• As required or permitted by law. We may disclose your personal information for compliance, fraud prevention and safety purposes. We may preserve or disclose your information if we believe that it is reasonably necessary to comply with a law, regulation, or legal request or to protect our and your safety, property, or rights. However, nothing in this Website Privacy Policy is intended to limit any legal defenses or objections that you may have to a third party or government request to disclose your information.
• With your consent. We may disclose your personal information with your consent and for any other purpose that we disclose to you when you provide the information.

We do not sell your personal information.

Information Security

In order to prevent unauthorized access or disclosure, we have put in place suitable physical, electronic and managerial procedures to safeguard and secure information. Nevertheless, due to the nature of the Internet and Internet technologies, security and privacy risks cannot be eliminated and we cannot guarantee that information will not be disclosed in ways not otherwise described in this Website Privacy Policy.

Children

Children are not eligible to use the Site. The Site and our services are not directed to, and we do not knowingly collect personal information from anyone under the age of 16.

Changes to this Privacy Policy

We may amend this Website Privacy Policy at our discretion and at any time and will indicate the effective date of the amended version.

Jurisdiction

This Site is operated and controlled by Accial’s primary office in the United States, and the content provided in or accessible through the Site is directed at residents of the United States. Access to the Site from countries or territories where such access is illegal is prohibited. Those who access the Site from outside the United States do so on their own initiative and are responsible for compliance with local laws, rules and regulations.