Allocate Holdings, Inc. and its affiliates (“Allocate,” “we,” “our,” and/or “us”) value the privacy of individuals who use our website and related services(collectively, our “Services”). This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information from or about Allocate users (“Users”) or their devices. Allocate offers investment products into Venture Capital Funds via feeder vehicles and direct investments. We facilitate these transactions through our online platform allowing Limited Partners the capability to research our products, request an investment allocation, and eventually invest in the product. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.
We may collect a variety of information from or about you or your devices from various sources, as described below.If you do not provide your information when requested, you may not be able to use our Services if that information is necessary to provide you with our Services or if we are legally required to collect it.
Registration and Profile Information. When you register to use our Services, we ask you for your name, email address, phone number, address, firm, and type of investor you are, and any other information we collect.
Payment Information. When you add a payment method to your account, a third party service that handles payment transfers for us will receive your personal or business financial account information.
Other Financial Information. Potential investors must qualify as an accredited investor or qualified purchaser under SEC guidelines. To confirm that you, as a potential investor, qualify under a net worth method, a third party service provider may collect additional financial information about you. We do not collect specific net worth data from that service provider. We only receive information regarding whether or not you are qualified to invest using our services under SEC guidelines.
Communications. If you contact us directly, we may receive additional information about you. For example, when you contact our Customer Support Team, we will receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide. If you subscribe to our newsletter, then we will collect certain information from you, such as your email address. When we send you emails, we may track whether you open them to learn how to deliver a better customer experience and improve our Services.
Careers. If you decide that you wish to apply for a job with us, you may submit your contact information and your resume online. We will collect the information you choose to provide on your resume, such as your education and employment experience. You may also apply through a job application portal, such as LinkedIn. If you do so, we will collect the information you make available to us through that job application portal.
Location Information. When you use our Services, if you allow us, we will receive your precise location information. We use your location information for research and customer service purposes. When you use our Services, we infer your more general location information (for example, your IP address may indicate your more general geographic region).
Device Information. We receive information about the device and software you use to access our Services, including internet protocol (IP) address, web browser type & version, operating system (OS) and version, email address, and User ID..
Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the pages or other content you view, the purchases you make or consider making, and the dates and times of your visits.
Information from Cookies and Similar Technologies. We and third party partners collect information using cookies, pixel tags, or similar technologies. Our third party partners, such as analytics and advertising partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings.
Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.
Credit Report and Background Checks. We work with third party partners to perform credit and background checks on potential investors, and receive publicly available information such as background check information, demographic data, and information about whether an investor is on any sanction or watchlists that would prohibit them from investing.
Third parties. We may receive information about you from third parties such as data or marketing partners and combine it with other information we have about you.
We use the information we collect:
We may share or otherwise disclose information we collect from or about you as described below or otherwise disclosed to you at the time of the collection.
Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services.
Marketing. We do not rent, sell, or share information about you with non affiliated companies for their direct marketing purposes, unless we have your permission.
Analytics Partners. We use analytics services such as Google Analytics to collect and process certain analytics data. These services may also collect information about your use of other websites, apps, and online resources. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners/, and opt-out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety. For the avoidance of doubt, the disclosure of your information may occur if you post any objectionable content on or through the Services.'
Merger, Sale, or Other Asset Transfers. We may disclose and transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our business or assets.
Google Identity Platform. Allocate integrates with Google Identity Platform (GIP) to provide you with social login and authentication services. Allocate collects your email address and shares your login information with Google for verification and authentication. Please note that Allocate does not have access to your Google account to enable the GIP function.
Consent. We may also disclose information from or about you or your devices with your permission.
Location Information. You can prevent your device from sharing precise location information at any time through your device’s operating system settings.
Marketing Communications. You can unsubscribe from our promotional emails via the link provided in the emails. Even if you opt-out of receiving promotional messages from us, you will continue to receive administrative messages from us.
Our Services may contain links to other websites, products, or services that we do not own or operate. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.
We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as our Services are hosted electronically, we can make no guarantees as to the security or privacy of your information
We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at support@allocate.co.
Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.
If you have questions about your privacy on the Services or this privacy policy, please contact us at privacy@allocate.co.
We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.
Allocate is responsible for processing your information. If you have any questions, comments, or concerns about our processing activities, please email us at support@allocate.co or write to us at 3790 El Camino real, Unit # 536, Palo Alto, CA 94306.
Last Updated: 10/01/2021