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Our commitment to you

As a Alfa99 investor or prospective investor, you may entrust to our care not only your money but your personal and financial information as well. We recognize that your relationship with us is based on trust, and that you expect us to act responsibly and in your best interests. When we share client or prospective client information—whether it is your personal information or the fact that you are or may become a Alfa99 client—we do so under the circumstances described in this policy.

We use your personal information primarily to respond to your inquiries or requests; to maintain and protect your accounts; to process transactions that you submit; to fulfill our legal obligations; for research and analytical purposes; and to develop, offer, and provide the financial products and services that we offer or sponsor.

The personal information we collect about you

The types of personal information we collect and share depend on the product or service you have with us. Examples of personal information we collect may include, among other things, your name and address, Social Security or taxpayer identification number, date of birth, assets, income, account balances, investment activity, accounts at other institutions, and information collected through your use of our website.

You provide personal information when you complete a Alfa99 account application. (If you enter information in an online account application, we may store the information even if you don't complete or submit the application.) You also provide personal information when you request information or materials from us or otherwise interact with Alfa99, as well as when you transact in your accounts.

In addition to personal information you provide to us, we may receive information about you that you authorize other parties to provide to us. We also may obtain personal information from service providers not affiliated with Alfa99 in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you. The information we collect about you may be transferred to or stored by Alfa99 or our service providers in the United States or elsewhere, as permitted by law.

We may combine the information collected on our website or through our mobile application with information collected from or about you in other contexts. This may include information collected online, such as through cookies or our email exchanges with you, or from offline sources, such as when you establish your account with us or call customer service. We will treat such combined information in accordance with this policy. If you do not wish to provide information to Alfa99, we may be unable to provide certain products or services to you.

How we use and disclose your personal information

We may use and share your personal information when needed to complete transactions at your request, to provide our services, to make you aware of financial products and services that we offer, to market or advertise our products or services, or where legally compelled to do so. Here are the details:

  • checkIn order to complete certain transactions or account changes that you direct, it may be necessary to provide identifying information about you to companies, individuals, or groups that are not affiliated with Alfa99. For example, if you ask to transfer assets from another financial institution to Alfa99, we will need to provide certain information about you to that institution to complete the transaction, including but not limited to your name and relevant account information.
  • checkIn order to alert you to other financial products and services that Alfa99 offers or sponsors, we may share your information within the Alfa99 family of affiliated companies, to the extent permitted by law. This would include, for example, sharing your contact information and information about your current product and service usage within Alfa99 to make you aware of new Alfa99 funds or other investment offerings, advice services, brokerage services, or asset management and trust services.
  • checkIn certain instances, we contract with service providers to perform services for us. Where necessary and in accordance with legal requirements, we may disclose any personal information we have about you to these service providers. In all such cases, we provide the service providers with information about you only as necessary to carry out its responsibilities as provided in its agreement with us, and only for that purpose. And we require these service providers to treat your information with the same high degree of confidentiality that we do.
  • checkIn order to market our products and services, we engage non-financial companies to show you relevant advertisements while you browse other websites or use social media. For further information on these activities, please see the section titled Interest-Based Advertising, below.
  • checkFinally, we will release information about prospective, current, or former customers if you direct or authorize us to do so, if we are compelled by law or legal process to do so, or in other legally limited circumstances (for example, to prevent fraud).

Cookies, web beacons, and online privacy

Our website and our mobile application use some of the most secure forms of online communication available, including data encryption, transmission encryption, usernames and passwords, adaptive authentication techniques, and back-end fraud and account monitoring. These technologies provide a high level of security and privacy when you access your account information, initiate online transactions, or send secure messages.

We use a variety of online technologies, as described further below, to collect information that helps us understand how our website and our mobile application are used. Specifically, when you visit Alfa99 online, we or our service providers may automatically collect a variety of technical and navigational information about you via these technologies, including, as applicable: your computer or device type; operating system version; browser type and version; user agent string; internet connection type; mobile network provider; date and time of your visit; time since your last visit; pages you view; links you select; searches you conduct; the internet protocol (IP) address used to access our website or mobile application; your general geographic location (e.g., your city, state, or zip code); and the website visited before our site. We also may use similar tracking technologies in emails that we or our service providers send to you, as further described below. This information may be used for purposes, including: to alert you to software compatibility issues, to resolve technical or service problems, and for security purposes. We also analyze this information, with the assistance of our service providers and to the extent permitted by law, to improve our website and mobile application design and functionality, to enhance our ability to serve you and your accounts, and to tailor our communications to you regarding our products and services.

Cookies

A cookie is a small file of letters and numbers that is stored on your computer or other device when you visit a website or a mobile application. Cookies contain information that is transferred to or read on your device and allow websites and mobile applications to recognize devices and store certain information, such as user preferences. Cookies are used to distinguish you from other users of our online services. This helps us to personalize and improve your user experience and help enhance site navigation, and to develop, offer, and provide our products and services to you. Cookies also help us to understand how people use our online services so that we can improve their structure, functionality, security, and content. We and our service providers use session cookies, which link your actions during a particular online session and expire at the end of that session, as well as persistent cookies, which remain on your device and allow us to remember your actions or preferences across multiple browser sessions.

If you are concerned about having cookies on your computer or other device, you can set your web browser to refuse all cookies or to indicate when a cookie is being set, allowing you to decide whether to accept it. You can also delete cookies from your device. The help feature on most web browsers will tell you how to prevent your browser from accepting new cookies, how to receive notice when a new cookie is set, and how to disable cookies altogether. However, if you choose to block or delete cookies, certain features of our website or our mobile application may not operate correctly. Information about how to opt out of the use of cookies for certain purposes (such as Interest-Based Advertising) is discussed below in the section titled Your opt out rights.

Web beacons

Our website, our mobile application, and the emails that you receive from Alfa99 use an application known as a web beacon (also known as a pixel tag or clear gif). A web beacon is an electronic file that usually consists of a single-pixel image, embedded in a web or mobile application page or an email to measure usage and activity. In some cases, a web beacon triggers the placement of a persistent cookie on your device. Web beacons allow us, directly or through our service providers, to collect information used for website and mobile application analytics, such as how many users have visited particular pages or downloaded documents, or how frequently users search for a particular term. We and our service providers also use web beacons and cookies to determine whether and when you receive and open our emails, and whether you select any links in an email. However, we do not use them to view or collect data in cookies or similar data files created by other websites. For further information on how we and our service providers collect and use such information, and to learn more about how to opt out of such information sharing, please visit the sections titled Interest-Based Advertising and Your opt out rights, below.

Third Party Websites/Online Services. Our website includes links to third-party sites or information that we think may be of interest to you. When you select these links and leave our website, our site's terms and conditions of use and privacy policy no longer apply. You are responsible for complying with the third-party site's terms of use and understanding its privacy policy, both of which you should review carefully.

Our website may enable you to share information directly with websites or online services operated by third parties. For example, our site contains features that allow you to share articles or content through Facebook, Twitter, LinkedIn, and other services, and to view content through video players and other services (such as the YouTube video player). If you choose to use these features, you may disclose information to those websites or services and their users, and to the public more generally. Even if you do not select these plug-in features, these third parties may collect information about you, such as your IP address and the pages that you view, and they may also set and/or access a cookie on your device. Because these third-party websites and services are not operated by Alfa99, we are not responsible for their content or practices. The collection, use, and disclosure of information through these websites and services are subject to the privacy policies of the third-party websites or services.

Analytics

We engage service providers to collect the information discussed above to engage in analysis, auditing, research, and reporting. These service providers may set and access cookies on your computer or other device and may use web beacons to collect information about your activity on our website or our mobile application.

Adobe Analytics. Our website and mobile application use Adobe Analytics to help collect and analyze certain information for the purposes discussed above. The information generated about your use of our online services may be transmitted to and stored by Adobe Analytics on servers outside your country of residence.

Google reCAPTCHA. We have implemented Google reCAPTCHA (“reCAPTCHA”) on our website to enhance your online account security and prevent fraud. This service is provided by Google LLC (“Google”). We use reCAPTCHA to determine whether an input is made by a natural person or by automated technology. reCAPTCHA analyzes and collects certain personal information about website visitors, including but not limited to: IP address, cookies, mouse movements, and length of stay on the website. By using reCAPTCHA, your personal information may be transferred to Google and other third parties to confirm that you are a human being and not an automated processor or spam bot.

Interest-Based Advertising

We also engage service providers, including social networks, to provide targeted advertising services that are customized based on your online activities over time and across unaffiliated websites (Interest-Based Advertising) and to help us measure brand awareness and the effectiveness of our online advertising. These service providers may use cookies, web beacons, and other similar technologies to collect information about your activity on our website, and they may combine it with information about your activity on other, unaffiliated websites. We and our service providers may use data collected on our website or when you open emails from Alfa99, together with other information we have about you and your Alfa99 relationships, to serve Alfa99 ads to you on their platforms and other sites as you browse the web. For example, we may share your email address with our advertising service providers so that they can target ads for Alfa99 products and services to you on non-Alfa99 websites. In addition, our advertising service providers might use information collected during your use of our online services, including limited demographic information (e.g., age), to help target non-Alfa99 advertisements based on your online activity in general.

We may use service providers’ technologies that enable us to establish connections among related devices (such as smartphones, tablets, and computers). This means that information about your interactions with our online services and online advertising through different devices may be combined. By making these connections, we may be able to better understand the relevance of our content and the impact of our advertising and to customize that content and advertising for you.

How we safeguard your personal information

Within Alfa99, we restrict access to information about you to those Alfa99 employees who need to know the information in order to perform their jobs, such as servicing your accounts, providing you with information you request, or notifying you of new products and services. To protect your personal information, we maintain physical, electronic, and procedural safeguards in keeping with industry standards and practices, and we review and adjust these safeguards regularly in response to advances in technology.

Safeguard your account information. For your protection, you should not provide your account information, username, or password to anyone. If you become aware of any suspicious activity relating to your account or if you suspect fraud, please call us at (305) 777-6952 or email us at mail@alfa99llc.com.

Review your account information. Alfa99 offers a variety of options for accessing and reviewing your account information. You can review your information on your statements and other account documents, as well as through our automated phone services and website. You may also write or call us with your request for information. Specific website addresses, mailing addresses, and phone numbers are listed on your account statements and other Alfa99 correspondence.

Website not for children

Our website and apps are neither intended for, nor targeted to children under 16, and we do not collect personal information directly from children under 16. We receive limited personal information about children from parents and other responsible adults only as required to establish and maintain accounts for the children’s benefit.

We will keep you informed

As required by federal law, we will notify you of our privacy policy annually. We reserve the right to modify this policy at any time, but rest assured that if we do change it, we will tell you promptly.

Contact Us

If you have questions about the way in which we have handled information about you, please do not hesitate to send us an email at mail@alfa99llc.com.