Privacy & Security Policy
Thank you for visiting the website of FrontGate Capital Group (“FCG”, “we” or “us”). An important part of our commitment to you is our respect for your privacy as a user of this website (the “Site”). This Privacy & Security Policy seeks to help you understand whether and how we collect information about you when you visit the Site, and how we use such information. Your visit to the Site is subject to this Privacy & Security Policy. By visiting the Site, you agree to this Policy in its entirety, which may be updated by us at any time. You should review this Privacy & Security Policy carefully. If you do not agree with it, you should not use the Site.
In the course of serving you as an individual client, investor and/or as someone associated with a corporate and/or institutional client or investor, FCG may obtain personal information about you. Obtaining this information is important to our ability to deliver the highest level of service to you, but we also recognize that you expect us to treat this information appropriately.
This policy describes the types of personal information we may collect about you, the purposes for which we use the information, the circumstances in which we may share the information and the steps that we take to safeguard the information to protect your privacy. As used throughout this policy, the term “FCG” refers to FrontGate Capital Group and its subsidiaries, affiliates and/or representatives worldwide.
This Privacy & Security Policy concerns only the Site and does not concern any website to which the Site may link. Should you choose to visit these third‐party sites, you should review their privacy policies to ensure that you understand and are comfortable with their practices concerning your personal information. Similarly, this Privacy & Security Policy does not concern your interaction with FCG in any matter other than your use of the Site. Finally, this Privacy & Security Policy does not address our privacy practices with respect to any nonpublic personal information we may collect from you as an investor in the investment opportunities or funds that we sponsor or manage. We address these practices in separate notices to investors or prospective investors.
If you have any questions or comments about this Privacy & Security Policy, you can write to us at FrontGate Capital Group, Attn: Website Administration, PO Box 1773, Roswell, Georgia, 30077‐1773, USA.
I. The Types of Information We Collect About You
When you enter and browse the Site, we may collect two different types of information about you: information you provide to us, and information we collect through technology.
A. Information You Provide to Us
In order to obtain access to certain information or materials provided via the Site, you may have to provide information that we collect and store in a way that allows us to relate it to you personally, including but not limited to your name, e‐mail address, mailing address, phone number, and/or facsimile number. We refer to such information as personally identifiable information. Additionally, we may collect and retain a record of all communications with you.
B. Information We Collect Through Technology
II. How Personally Identifiable Information We Collect About You is Used
FCG does not disclose any nonpublic personally identifiable information to any non-affiliated third party, except where permitted by law.
We may use your personally identifiable information in several ways.
Although we do not sell your personal information to third parties, we may use or share certain personally identifiable information we collect about you when you visit and browse the Site as part of our normal business operations, or to send you administrative communications either about your interactions with us or about features of the Site, including any future changes to this Privacy & Security Policy, to the extent permitted by law.
We may also store your personally identifiable information and share it with our subsidiaries and/or affiliates. We may use this information for marketing, research and other business purposes, and we may associate your personally identifiable information with other information we collect about you, such as details about your usage patterns and interests, in each case to the extent permitted by law.
We may also use service providers to facilitate our services or platform functions on our behalf. These companies and individuals may have access to your personally identifiable information, as permitted by law and as needed to perform their functions, but may not use it for another purpose.
We will disclose personal information when we believe that such disclosures are required by law, regulation, legal process or governmental request. We may also do so to help enforce our Terms & Conditions of Use, protect your safety or security, including the safety and security of property that belongs to you, or protect the safety and security of our websites, databases or third parties, including the safety and security of tangible or intangible property that belongs to us or to third parties. Also, in the event that FCG, or substantially all of its assets, are acquired or merged with another entity, user information may be one of the transferred assets. You will receive a notice if such an event occurs. FCG, however, reserves the right to use any personal information in any manner permitted by law.
III. How Non‐Personally Identifiable Information We Collect About You is Used
Non‐personally identifiable information is information that does not personally identify you, including anonymous information and aggregate data. We may use this information to understand better how our visitors use the Site, research our visitors’ demographics, interest, and behavior, improve the Site, provide visitors with customized services and information, and for other similar purposes. We may combine this information with personally identifiable information. We may share this information with others, such as investors, for information or promotional purposes to the extent permitted by law. FCG, however, reserves the right to use this information in any manner permitted by law.
IV. Protection of Information; No Guarantee of Security
We endeavor to protect your personal information. We use both technical and procedural methods to maintain the integrity and security of our databases, including firewalls. Please be aware though that no security measures are perfect or impenetrable. We will not be responsible or liable for any damages, losses or causes of action arising out of or in connection with the disclosure of your personally identifiable information.
V. Amendments to this Privacy & Security Policy
We may revise this Privacy & Security Policy from time to time. If we make any substantial change to our Privacy & Security Policy, we will post a prominent announcement on the Site and will post the updated Privacy & Security Policy here. Any such changes will be effective upon posting.
VI. International Use, Governing Law and Forum
FCG makes no claims that materials on the Site are appropriate or may be downloaded for use in locations outside the United States of America. Access to the Site from countries or territories where such access is illegal is prohibited. Those who choose to access the Site outside the United States of America do so at their own initiative and are responsible for compliance with local and/or international laws.
This Privacy & Security Policy is governed by State of Florida law. Any dispute regarding this Privacy & Security Policy or your use of the Site shall be resolved solely in the state or federal courts located in Miami‐Dade County, Florida, USA.
Last updated: January 2015.
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