This Privacy Policy applies to our services available under the domain and subdomains of www.contextfunds.com (the “Site”). This Privacy Policy outlines how Context Capital Management, LLC (“Context”) collects, uses, discloses, updates, and protects the types of personal information we may gather when you visit our Site or use our services. By visiting the Site, you agree to be bound by the terms and conditions of this Privacy Policy. If you do not agree, please do not use or access the Site.
By accepting the Privacy Policy and the Terms of Use, you expressly consent to our use and disclosure of your personal information in accordance with this Privacy Policy. This Privacy Policy is incorporated into and subject to the Terms of Use.
Online Information Collected
We have adopted general policies and procedures concerning confidentiality, proprietary data and privacy of customer personal information, and the limited information we gather over the Site is protected by those policies and procedures. This Privacy Policy applies only to information collected from, or which may be submitted to, the Site. Generally, we collect non-public personal information about our clients and investors from information we receive on applications and other forms, including information collected on the Site, and information about clients’ or investors’ transactions with us, our affiliates or others.
We intend to use analytics cookies or similar services to track certain information that your browser makes available whenever you visit a website. This information includes your Internet Protocol address, browser type, browser language and one or more files that may uniquely identify your browser. We use that information as described below in “Use and Disclosure of Information” below. Besides that information, you can browse the non-password protected sections of the Site without telling us who you are or revealing any other personal information about yourself
Use and Disclosure of Information
We use the information we collect from our browser and data collection devices such as cookies to analyze Site usage, improve our content and product offerings and customize the Site’s content, layout, and services. We may also use information collected from you to customize your experience and enforce our Terms of Use. We may use your information to send correspondence and perform services on your behalf in connection with investment related activities.
We do not disclose any non-public personal information collected from this Site to anyone, except as permitted by law. We reserve the right to disclose any such information when required by a valid subpoena or court order, or as otherwise permitted or required by law to service providers and regulatory authorities in connection with our business or our affiliates.
We cannot ensure that all of your private communications and other personal information will never be disclosed in ways not otherwise described in this Privacy Policy. We may be forced to disclose personal information to the government or third parties under certain circumstances, third parties may unlawfully intercept or access transmissions or private communications, or service providers may abuse or misuse your personal information that they collect from the Site. Although we use industry standard practices to protect your privacy, we do not promise, and you should not expect, that your personal information or private communications will always remain private.
Control of Your Personal Information
Under the California Consumer Privacy Act (“CCPA”), residents of California have the following rights: (1) to request a description of the categories information we have collected about you in the last 12 months, (2) to request the specific pieces of personal information we have about you, and (3) to request a copy of the personal information we have about you twice in a 12-month period. We will provide that information to you within 45 days of such a request. Before we send you such information, however, we will use reasonable efforts to verify that the request is from you depending on the request.
California residents also have the right to request us to delete your personal information from our records, except to the extent we are required by law to retain any record. We will request you to verify such a request to delete your data in the same manner.
You have a right not be discriminated against for the exercise of the privacy rights conferred by California law.
Enforcement
You may seek to learn more about what personal information of yours is being processed, how and why such information is processed, and the third parties who have access to such personal information (if any). You may object to further use or disclosure of your personal information in certain circumstances. You have the right to review and change or complete the information you provide to us by contacting us at compliance@contextfunds.com. You must promptly update your personal information if it changes or is inaccurate.
Security
We maintain physical, electronic, and procedural safeguards that comply with federal standards to guard your personal information. Your information is stored on our servers located in the United States or in a cloud environment. We use procedural and technical safeguards to protect your personal information against loss or theft as well as unauthorized access and disclosure, which may include encryption, “firewalls” and Secure Socket Layers.
It is possible, however, that a third party will circumvent such security measures, and we do not guarantee that our security measures will successfully prevent third parties from accessing the information we collect. In the event of a security breach involving your personal information, we will make any legally required disclosures to you in the most expedient time possible and without unreasonable delay, consistent with the legitimate interests of law enforcement, or any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.
Phishing
Identity theft and the practice currently known as “phishing” are of great concern to us. Safeguarding information to help protect you from identity theft is a top priority. We do not and will not, at any time, request your username, credit card information or national identification number in an unsolicited e-mail or telephone communication. For more information about phishing, visit the Federal Trade Commission’s website.
Children
Children (persons under the age of 18) are not eligible to use the Site and, therefore, we do not knowingly collect any personal information from persons under the age of 18.
Conditions
If you choose to visit the Site, your visit and any dispute over privacy is subject to this Privacy Policy and our Terms of Use, including limitations on damages and application of the law of the State of California. If you have any concern about privacy, or if you wish to make any requests as listed above for California residents, please send a thorough description to compliance@contextfunds.com.
Changes to this Privacy Policy
This Privacy Policy may change from time to time. We may amend this Privacy Policy at any time by posting the amended terms on the Site. All amended terms shall automatically be effective 30 days after they are initially posted on the Site. Your continued use of the Site constitutes your agreement to this Privacy Policy and any changes to this Privacy Policy. If we make any material changes to this Privacy Policy that affect your information already stored in our database, we will post a prominent notice on the Site stating that this Privacy Policy has changed. If you do not agree with this Privacy Policy or any changes to the Privacy Policy, please do not use or access the Site.
If you have any additional questions, please feel free to contact us any time at compliance@contextfunds.com.