Additional Information for California Residents
The CCPA imposes certain obligations on us and grants certain rights to California residents (“California Resident,” “you” or “your”) with regard to “personal information.” If you are a California Resident, please review the following information about your potential rights with regard to your personal information under the CCPA. The rights described herein are subject to exemptions and other limitations under applicable law.
Terms used herein have the meaning ascribed to them in the CCPA. We are a “business.”
Notice at Collection and Use of Personal Information
Information We Collect
Depending on how you interact with us, we may collect the categories of personal information listed above in the section Collection of Personal Data.
How We Use Collected Information
We also may use personal information from you for the business or commercial purposes described above in the section Why We Collect Your Personal Data.
How Long We Keep Information
We retain your personal information as described above in How Long We Retain Your Personal Data.
Sale or Sharing of Personal Information
We may disclose the categories of personal information listed above in Collection of Personal Data to certain third parties in support of our marketing and advertising efforts in a way that could be considered a “sale” or “sharing” of personal information under the CCPA. Under the CCPA, you have the right to opt-out of the “sale” or “sharing” of your personal information, which can be exercised here.
For more information about our privacy practices, please review our entire Privacy Policy, which is available starting on the first page of this document.
Our Collection, Use, and Disclosure of Personal Information and Sensitive Personal Information
What Information We Have Collected, the Sources from Which We Collected It, and Our Purpose for Collecting It
In the preceding 12 months, depending on how you interact with us, we may have collected the categories of personal information listed above in the section Collection of Personal Data. We may collect personal information from all or some of the categories of sources listed in the section Sources of Personal Data. We may collect all or a few of these categories of personal information for the business or commercial purposes identified in the section Why We Collect Your Personal Data.
Our Disclosure of Personal Information
We do not knowingly sell or share the personal information of minors under 16 years old. In the preceding 12 months, we may have disclosed for a business purpose the following categories of personal information to the following categories of third parties, as describe in the below chart:
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Category of Personal Information |
Category of Third Party |
|---|---|
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Identifiers (for example your name, address, DOB, SSN, driver’s license, passport number and online identifiers) |
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Additional information subject to Cal. Civ. Code § 1798.80(e) (for example, a signature, state identification card number, financial information, or bank account information) |
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Characteristics of protected classifications under certain federal or state laws (for example gender, age, national origin, citizenship, or marital status) |
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Commercial Information (for example records of products or services purchased, obtained, or considered or purchasing histories or tendencies including funds in which you are invested, investments considered or sources of wealth) |
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Internet or Electronic Network Activity Information (including interactions with our Website or use of certain online tools) |
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Education Information, including information that is not publicly available, personally identifiable information as defined in the Family Educational Rights and Privacy Act |
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Audio (e.g., voicemail), electronic, visual, or similar information |
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Professional or Employment Related Information, including occupation, compensation, employer, and title |
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Inferences drawn from any of the information identified above to create a profile reflecting your preferences or similar information, including your potential interest in investing in new funds |
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While we have not “sold” your personal information in the ordinary sense, in the preceding 12 months, we may have “sold” or “shared” (as such terms are defined under the CCPA) the categories of personal information to the categories of third parties, described in the chart below, including:
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Category of Personal Information |
Category of Third Party Sold To or Shared With |
|---|---|
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Identifiers (for example your name, address, and online identifiers) |
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Internet or Electronic Network Activity Information (including interactions with our Website or use of certain online tools) |
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We have not and will not make personal information available to third parties for monetary consideration.
In addition, in the preceding 12 months, we may have disclosed for all of the categories of personal information identified in “Collection of Personal Data” above, to the following categories of third parties: (i) judicial courts, regulators, or other government agents purporting to have jurisdiction over us, our subsidiaries or our affiliates, or opposing counsel and parties to litigation; (ii) any relevant third party acquirer(s), in the event that we sell or transfer all or any relevant portion of our business or assets; and (iii) other third parties as may otherwise be permitted by law. We may disclose personal information to all of the third parties listed above to comply with our legal obligations or for the purposes identified in Why We Collect Your Personal Data. We may “share” or “sell” the categories of personal information to the third parties listed above for the business or commercial purposes identified in Why We Collect Your Personal Data.
We may transfer to another entity or its affiliates or service providers some or all information about you in connection with, or during negotiations of, any merger, acquisition, sale of assets or any line of business, change in ownership control, or financing transaction. We may also share your personal information with our service providers such as our administrator, IT providers, or CRM provider, other entities that have agreed to limitations on the use of your personal information, or entities that fit within other exemptions or exceptions in, or as otherwise permitted by, the CCPA.
Our Use and Disclosure of Sensitive Personal Information
As noted above in Collection of Personal Data, under the CCPA, certain personal information we collect and process may be considered “sensitive personal information.” The CCPA requires that we provide you with the right to limit our use or disclosure of such sensitive personal information in certain circumstances. Currently, we are not using your sensitive personal information for purposes that would require that we provide you with a right to limit.
California Residents’ Rights under the CCPA
If your personal information is subject to the CCPA, you may have certain rights concerning that information, subject to applicable exemptions and limitations, including the right to: (i) be informed, at or before the point of collection, of the categories of personal information to be collected and the purposes for which they will be used; (ii) not be discriminated against for exercising your rights under the CCPA; (iii) request deletion of your personal information, subject to certain exceptions (“Request to Delete”); (iv) opt-out of the sale of your personal information; (v) opt-out of the sharing of your personal information with third parties; (vi) limit the use and disclosure of sensitive personal information where required (“Right to Limit”); (vii) correct inaccurate personal information (“Request to Correct”); and (viii) request disclosure (“Request to Know”) of: (a) categories of personal information collected; (b) sources of the information; (c) purpose of collection; (d) categories of third parties with whom it is shared; and (e) specific pieces of personal information collected.
The CCPA does not restrict our ability to do certain things like comply with other laws or comply with regulatory investigations. In addition, the CCPA does not apply to certain information like personal information collected, processed, sold, or disclosed pursuant to the federal Gramm-Leach-Bliley Act and its implementing regulations. We also reserve the right to retain, and not to delete, certain personal information after receipt of a Request to Delete from you where permitted by the CCPA or another law or regulation.
How to Submit a Request under the CCPA
You may submit a Request to Know, Request to Delete or Request to Correct (“Consumer Rights Request”) as described above, through the following toll-free telephone number 800-604-LIDO, through our Website at the following link: https://www.lidoadvisors.com/contact-us/, or email us at compliance@lidoadvisors.com.
We are only required to respond to verifiable Consumer Right Requests made by you or your legally authorized agent. When you submit a Consumer Rights Request, we may ask that you provide clarifying or identifying information to verify your request. Such information may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, your name and email address. Any information gathered as part of the verification process will be used for verification purposes only.
You are permitted to designate an authorized agent to submit a Consumer Rights Request on your behalf and have that authorized agent submit the request through the aforementioned methods. In order to be able to act, authorized agents have to submit proof that they are authorized to act on your behalf, or have a power of attorney. We may also require that you directly verify your own identity with us and directly confirm with us that you provided the authorized agent permission to submit the request.
Changes to this Privacy Policy
We reserve the right to change this Privacy Policy at any time. Revised versions of the Privacy Policy will be made available on this Website with the revision date, and to investors via email. You may have additional rights under other foreign or domestic laws that may apply to you, including as set forth in additional privacy notices.
How to Contact Us
This Privacy Policy is available in alternative formats upon request. If you have any questions concerning this Privacy Policy, or to request this Privacy Policy in an alternative format, please contact us at compliance@lidoadvisors.com.
